Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: For one student, the College under awarded Pell. Questioned Costs: None Context: In our testing, we noted that 1 of the 38 students tested that received Pell, was under awarded based on their expected family contribution (EFC) and enrollment status. Cause: It was noted that the new software used to prepare the student award packages had errors in the disbursement schedule that was used to determine the Pell awards. Effect: One student was under awarded Pell Grant. Repeat Finding: Yes. Prior year Finding 2021-005. Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The U.S. Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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 report Direct Loan disbursements within the required 15 days. Questioned Costs: None Context: During our testing, we noted two Direct Loan disbursements of the 40 Pell and Direct Loan disbursements tested were not reported to COD within the required 15 days. The two disbursements were for the same student. Cause: The student's master promissory note had expired by the time the student's third disbursement for fiscal year 2022 was made. Because of this, the College?s software would not report the disbursement date to COD. The College manually applied the disbursement date in COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding number was 2021-003. Recommendation: We recommend the College evaluate the limitations of their software around COD reporting and establish procedures and policies that address any limitations around reporting disbursements to COD to ensure that student information is reported timely. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The 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 (34 CFR 668.165). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: We tested notifications of loan disbursements and noted only a general notification of disbursements went out stating the date that funds were anticipated to be disbursed to student accounts in general. The required elements of the notification of disbursements were not met by this blanket notification. Questioned Costs: None Context: In our testing, we noted that seven of the seven students tested that receive Loans did not receive a notification of disbursements. Cause: The College did not send award disbursement notifications to students at the time of the loan disbursement. Effect: The College was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. 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 of the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal 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. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: The College did not comply with timely and accurate reporting for the Quarterly Student and Institutional program. Questioned Costs: None Context: During our testing of the reporting process, we noted: ? Three of three of the quarterly student reports tested were not posted timely. ? One of three of the quarterly student reports tested were not reviewed and approved prior to submission. ? One item of the quarterly student report was unable to be supported with supporting documentation. ? Three items of the quarterly student reports tested did not agree to supporting documentation. ? 2 of the 2 quarterly institutional reports tested were not published timely. ? 2 of the 2 quarterly institutional reports tested were not reviewed and approved prior to submission. Cause: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, the College did not have a proper system in place to retain all documentation and ensure the information in the reports had supporting information. Effect: The College was not in compliance with the U.S. Department of Education (ED) regulations for timely and accurate HEERF reporting. In addition, it was possible for errors to occur in the reports and not be caught due to lack of review. Repeat Finding: Yes. Prior year finding 2021-009 Recommendation: We recommend the College review their reporting procedures to ensure all reports are submitted timely and the supporting documentation used to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The student emergency financial aid grant is provided to the student, and may be used by the student for any component of the student's cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care, or child care. Institutions may not compel a student to use a portion of their grants to satisfy any existing debts or balance. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: A portion of the HEERF Student Aid Portion funds were awarded to students only if the student signed and returned a letter authorizing the College to use those funds to pay off their account balance for five terms. Questioned Costs: $143,186 Context: We performed testing over 40 disbursements made to students from the HEERF Student Aid Portion disbursements noting 10 of the disbursements were unallowable. The College drew down federal funding from the student portion award to cover the costs incurred. The College also reported the disbursements made on their quarterly reporting. Cause: The College sent letters to students notifying them of available funding and requesting their permission to use the funding for that purpose. The letter indicated the funding would be made from Institution Portion of the HEERF funds. When applying the funds to the student accounts, the College used HEERF Student Aid Portion funds. Effect: The College was not in compliance with allowable costs under the HEERF Student Aid Portion requirements. As a result of this noncompliance, the College incorrectly drew down funds from the HEERF Student Aid Portion and reported unallowed costs on their quarterly reports for the student portion. Repeat Finding: No Recommendation: We recommend the College implement procedures to review HEERF funding sources before applying to expenditures to ensure appropriate application. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal 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. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: The College did not comply with timely and accurate reporting for the Quarterly Student and Institutional program. Questioned Costs: None Context: During our testing of the reporting process, we noted: ? Three of three of the quarterly student reports tested were not posted timely. ? One of three of the quarterly student reports tested were not reviewed and approved prior to submission. ? One item of the quarterly student report was unable to be supported with supporting documentation. ? Three items of the quarterly student reports tested did not agree to supporting documentation. ? 2 of the 2 quarterly institutional reports tested were not published timely. ? 2 of the 2 quarterly institutional reports tested were not reviewed and approved prior to submission. Cause: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, the College did not have a proper system in place to retain all documentation and ensure the information in the reports had supporting information. Effect: The College was not in compliance with the U.S. Department of Education (ED) regulations for timely and accurate HEERF reporting. In addition, it was possible for errors to occur in the reports and not be caught due to lack of review. Repeat Finding: Yes. Prior year finding 2021-009 Recommendation: We recommend the College review their reporting procedures to ensure all reports are submitted timely and the supporting documentation used to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: For one student, the College under awarded Pell. Questioned Costs: None Context: In our testing, we noted that 1 of the 38 students tested that received Pell, was under awarded based on their expected family contribution (EFC) and enrollment status. Cause: It was noted that the new software used to prepare the student award packages had errors in the disbursement schedule that was used to determine the Pell awards. Effect: One student was under awarded Pell Grant. Repeat Finding: Yes. Prior year Finding 2021-005. Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The U.S. Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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 report Direct Loan disbursements within the required 15 days. Questioned Costs: None Context: During our testing, we noted two Direct Loan disbursements of the 40 Pell and Direct Loan disbursements tested were not reported to COD within the required 15 days. The two disbursements were for the same student. Cause: The student's master promissory note had expired by the time the student's third disbursement for fiscal year 2022 was made. Because of this, the College?s software would not report the disbursement date to COD. The College manually applied the disbursement date in COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding number was 2021-003. Recommendation: We recommend the College evaluate the limitations of their software around COD reporting and establish procedures and policies that address any limitations around reporting disbursements to COD to ensure that student information is reported timely. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The 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 (34 CFR 668.165). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: We tested notifications of loan disbursements and noted only a general notification of disbursements went out stating the date that funds were anticipated to be disbursed to student accounts in general. The required elements of the notification of disbursements were not met by this blanket notification. Questioned Costs: None Context: In our testing, we noted that seven of the seven students tested that receive Loans did not receive a notification of disbursements. Cause: The College did not send award disbursement notifications to students at the time of the loan disbursement. Effect: The College was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. 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 of the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV (34 CFR 668.34). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
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 as well as the program begin date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal 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. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal 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. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: The College did not comply with timely and accurate reporting for the Quarterly Student and Institutional program. Questioned Costs: None Context: During our testing of the reporting process, we noted: ? Three of three of the quarterly student reports tested were not posted timely. ? One of three of the quarterly student reports tested were not reviewed and approved prior to submission. ? One item of the quarterly student report was unable to be supported with supporting documentation. ? Three items of the quarterly student reports tested did not agree to supporting documentation. ? 2 of the 2 quarterly institutional reports tested were not published timely. ? 2 of the 2 quarterly institutional reports tested were not reviewed and approved prior to submission. Cause: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, the College did not have a proper system in place to retain all documentation and ensure the information in the reports had supporting information. Effect: The College was not in compliance with the U.S. Department of Education (ED) regulations for timely and accurate HEERF reporting. In addition, it was possible for errors to occur in the reports and not be caught due to lack of review. Repeat Finding: Yes. Prior year finding 2021-009 Recommendation: We recommend the College review their reporting procedures to ensure all reports are submitted timely and the supporting documentation used to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The student emergency financial aid grant is provided to the student, and may be used by the student for any component of the student's cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care, or child care. Institutions may not compel a student to use a portion of their grants to satisfy any existing debts or balance. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal 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: A portion of the HEERF Student Aid Portion funds were awarded to students only if the student signed and returned a letter authorizing the College to use those funds to pay off their account balance for five terms. Questioned Costs: $143,186 Context: We performed testing over 40 disbursements made to students from the HEERF Student Aid Portion disbursements noting 10 of the disbursements were unallowable. The College drew down federal funding from the student portion award to cover the costs incurred. The College also reported the disbursements made on their quarterly reporting. Cause: The College sent letters to students notifying them of available funding and requesting their permission to use the funding for that purpose. The letter indicated the funding would be made from Institution Portion of the HEERF funds. When applying the funds to the student accounts, the College used HEERF Student Aid Portion funds. Effect: The College was not in compliance with allowable costs under the HEERF Student Aid Portion requirements. As a result of this noncompliance, the College incorrectly drew down funds from the HEERF Student Aid Portion and reported unallowed costs on their quarterly reports for the student portion. Repeat Finding: No Recommendation: We recommend the College implement procedures to review HEERF funding sources before applying to expenditures to ensure appropriate application. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-federal 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. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: The College did not comply with timely and accurate reporting for the Quarterly Student and Institutional program. Questioned Costs: None Context: During our testing of the reporting process, we noted: ? Three of three of the quarterly student reports tested were not posted timely. ? One of three of the quarterly student reports tested were not reviewed and approved prior to submission. ? One item of the quarterly student report was unable to be supported with supporting documentation. ? Three items of the quarterly student reports tested did not agree to supporting documentation. ? 2 of the 2 quarterly institutional reports tested were not published timely. ? 2 of the 2 quarterly institutional reports tested were not reviewed and approved prior to submission. Cause: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the College did not have a process to track the reporting requirements. In addition, the College did not have a proper system in place to retain all documentation and ensure the information in the reports had supporting information. Effect: The College was not in compliance with the U.S. Department of Education (ED) regulations for timely and accurate HEERF reporting. In addition, it was possible for errors to occur in the reports and not be caught due to lack of review. Repeat Finding: Yes. Prior year finding 2021-009 Recommendation: We recommend the College review their reporting procedures to ensure all reports are submitted timely and the supporting documentation used to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding.