Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer.
Condition: Of the 27 students selected for testing, 13 students had errors in enrollment status; the institution's record did not match what was reported to NSLDS. 3 students tested did not have enrollment data certified every 60 days. Additionally, 1 student’s enrollment status was not reported timely to NSLDS.
Questioned Costs: None
Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are accurate and timely.
Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. The effective date should be the student's last date of attendance and academically-related activity.
Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period.
Repeat Finding: Yes, see finding 2023-001.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations.
Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Material Weakness in Internal Control Over Compliance
Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS. Likewise, the College did not have a formal review of their award packaging during the 2023-24 academic year, R2T4 calculations, direct payment of FSA credit balances to students, return of excess credit refunds after 240 days, reporting of NSLDS enrollment to the clearinghouse, FISAP, and verification documents.
Questioned Costs: None
Context: The College did not have proper internal controls in place during the 2023-24 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties.
Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Repeat Finding: Yes, see finding 2023-002.
Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the College, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary.
Condition: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Questioned Costs: None
Context: During our testing, we noted the College did not perform monthly reconciliations for the months of October 2023 and November 2023.
Cause: The College’s management did not have the knowledge to complete the reconciliation or the time to learn the process or complete.
Effect: College is not complying with internal policy and federal requirements to ensure funds are properly reconciled.
Repeat Finding: No
Auditor’s Recommendation: We recommend that the College ensure its employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(h)(4)(ii) states within 30 days of the date of the institution's determination that the student withdrew, an institution must send a notice to any student who owes a title IV, HEA grant overpayment as a result of the student's withdrawal from the institution in order to recover the overpayment in accordance with paragraph (h)(4)(i) of this section.
Condition: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Questioned Costs: $306
Context: During out testing, we noted 1 of the 14 students tested did not have a return of funds to COD.
Cause: The College did not have a process in place to notify all students when they were required to return funds to the Department of Education.
Effect: Federal funds were not returned to the Department of Education and the student was not informed that they needed to do so.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s EFC and the enrollment status of the student.
Condition: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded
Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Questioned Costs: None
Context: During our testing, we noted 6 of the 40 students selected for eligibility testing were underawarded Pell for the fiscal year due to a system software limitation causing student to not be awarded for more than two semesters.
Cause: Pell grants were computed utilizing enrollment for no more than two semesters in the fiscal year, causing some students to be under-awarded.
Effect: Students were under-awarded Pell funds.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period.
Condition: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Questioned Costs: $306
Context: During our testing, we noted the calculation done for 1 of the 14 individuals tested had used an incorrect percentage of days attended, causing the College to incorrectly calculate the return of Title IV funds.
Cause: The College used the incorrect withdrawal date, causing the student’s percentage of days attended to be miscalculated.
Effect: The College is not completing accurate R2T4 calculations as defined by the regulations.
Repeat Finding: Yes, see finding 2023-007.
Auditor’s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are completed timely and accurately.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume.
Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan (NFL) balances on a regular basis.
Questioned Costs: None
Context: We noted there was no reconciliation process in place for NSL and NFL balances to ensure they are properly stated each period.
Cause: We noted there were not the proper policies and controls in place to make sure this reconciliation and review was occurring.
Effect: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate.
Repeat Finding: Yes, see finding 2023-008.
Auditor’s Recommendation: The College should ensure all necessary employees receive proper training, support, and time to follow the College's policies and federal requirements related to monthly reconciliations.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.51 through 668.61, requires an Institution to code a student's verification status in the Common Origination Disbursement (COD) system for Pell grant recipients.
Condition: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Questioned Costs: None
Context: During our testing, we noted 2 of the 8 students selected for verification testing had not been reported to COD during the fiscal year.
Cause: The College did not have a process in place to ensure students verification status was being reported to the Common Origination Disbursement (COD) system.
Effect: Verification status was not reported to the Common Origination Disbursement (COD) system.
Repeat Finding: No.
Auditor’s Recommendation: We recommend that a process is put in place to ensure that all students selected for verification are being reported to the Common Origination Disbursement (COD) system.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but:
(1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
(2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Condition: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Questioned Costs: $1,147
Context: During our testing, we noted 2 credit balances out of 40 tested where the credit balance was not refunded within the 14 day period.
Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14 day period.
Effect: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Aid
Assistance Listing Number: Student Financial Aid Cluster
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
Significant Deficiency in Internal Control Over Compliance
Other Matters
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP).
Condition: During our testing of reporting, we noted the FISAP information was originally incorrectly reported for both Part II, Section D. #7 and Part II, Section E. #22 and had to be updated.
Questioned Costs: None
Context: During our testing, we noted the FISAP had to be updated for the total number of students enrolled at the college as well as total tuition and fees during 2023-2024.
Cause: The college did not have proper procedures in place to ensure information reported on the FISAP was accurate.
Effect: The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately report information.
Repeat Finding: No.
Auditor’s Recommendation: We recommend the College review their policies and procedures surrounding FISAP reporting.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.