Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063
Federal Award Identification Number and Year P063P232032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College under-awarded funds for the Pell Grant.
Questioned costs:
Known $6,472.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student.
Cause Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester
Effect Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds.
Repeat Finding No
Recommendation We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.268
Federal Award Identification Number and Year P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Cash Management
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that Direct Loan Reconciliation was performed.
Questioned costs: N/A
Known
Likely
Context During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented.
Cause Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely.
Effect Failure to perform reconciliations timely could result in errors going undetected by student financial aid management.
Repeat Finding No
Recommendation We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.063
Federal Award Identification Number and Year P063P232032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "Per 34 CFR 690.62 states the Pell grant for an academic year is based
upon the payment and disbursement schedule published by the Secretary for each award year.
34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College under-awarded funds for the Pell Grant.
Questioned costs:
Known $6,472.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student.
Cause Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester
Effect Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds.
Repeat Finding No
Recommendation We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations.
Questioned costs:
Known $341.00
Likely See Questioned Cost Tab
Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations.
Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began.
Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned.
Repeat Finding No
Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date.
Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
"
Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records.
Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately.
Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding No
Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Special Test and Provisions
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly notify students when loans were credited to student's ledger account.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements.
Cause Due to staff turnover, loan notifications were missed being sent out to students.
Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time.
Repeat Finding No
Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.007, 84.038, 84.063, 84.268
Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Eligibility
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not properly have documentation of exit counseling notification.
Questioned costs: N/A
Known
Likely
Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification.
Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students.
Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment.
Repeat Finding No
Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner.
Views of Responsible Officials Agree
Federal Agency US Department of Education
Federal Program Name Student Financial Assistance Cluster
Assistance Listing Number 84.268
Federal Award Identification Number and Year P268K24032 - 2024
Pass-Through Agency (if applicable) N/A
Pass-Through Number(s) (if applicable) N/A
Award Period 7/1/2023-6/30/2024
Compliance Requirement Affected Cash Management
Type of Finding
Internal Control Significant Deficiency
Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance.
Compliance Not Material
Document judgment for your assessment Not greater than 5% and not a systemic failure
Criteria or specific requirement "The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed.
Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements."
Condition The College did not have documentation that Direct Loan Reconciliation was performed.
Questioned costs: N/A
Known
Likely
Context During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented.
Cause Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely.
Effect Failure to perform reconciliations timely could result in errors going undetected by student financial aid management.
Repeat Finding No
Recommendation We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month.
Views of Responsible Officials Agree