Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Reporting Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education. Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition: The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Cause: The College did not have a process in place to retain reporting documentation. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance: Supplement. Questioned costs: None identified. Context: The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Identification as a repeat finding: Previously reported as finding 2022-006. Recommendation: It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Enrollment Reporting: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268. US Department of Education: Significant Deficiency and Nonmaterial Noncompliance:Criteria or specific requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 11 of 56 program reporting details did not agree to enrollment details from the enrollment records per the College. 7 of 60 campus level reporting details did not have enrollment status that agreed to enrollment records per the College. 8 of 32 students did not have campus reporting completed within the required timeframe. Cause: The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Effect: The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs :None identified. Context: The College disbursed financial aid to approximately 404 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 404 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2022-008. Recommendation: The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Reporting Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education. Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition: The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Cause: The College did not have a process in place to retain reporting documentation. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance: Supplement. Questioned costs: None identified. Context: The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Identification as a repeat finding: Previously reported as finding 2022-006. Recommendation: It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Enrollment Reporting: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268. US Department of Education: Significant Deficiency and Nonmaterial Noncompliance:Criteria or specific requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 11 of 56 program reporting details did not agree to enrollment details from the enrollment records per the College. 7 of 60 campus level reporting details did not have enrollment status that agreed to enrollment records per the College. 8 of 32 students did not have campus reporting completed within the required timeframe. Cause: The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Effect: The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs :None identified. Context: The College disbursed financial aid to approximately 404 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 404 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2022-008. Recommendation: The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Reporting Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education. Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition: The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Cause: The College did not have a process in place to retain reporting documentation. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance: Supplement. Questioned costs: None identified. Context: The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Identification as a repeat finding: Previously reported as finding 2022-006. Recommendation: It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Enrollment Reporting: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268. US Department of Education: Significant Deficiency and Nonmaterial Noncompliance:Criteria or specific requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 11 of 56 program reporting details did not agree to enrollment details from the enrollment records per the College. 7 of 60 campus level reporting details did not have enrollment status that agreed to enrollment records per the College. 8 of 32 students did not have campus reporting completed within the required timeframe. Cause: The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Effect: The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs :None identified. Context: The College disbursed financial aid to approximately 404 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 404 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2022-008. Recommendation: The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Reporting Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education. Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition: The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Cause: The College did not have a process in place to retain reporting documentation. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance: Supplement. Questioned costs: None identified. Context: The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Identification as a repeat finding: Previously reported as finding 2022-006. Recommendation: It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Enrollment Reporting: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268. US Department of Education: Significant Deficiency and Nonmaterial Noncompliance:Criteria or specific requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 11 of 56 program reporting details did not agree to enrollment details from the enrollment records per the College. 7 of 60 campus level reporting details did not have enrollment status that agreed to enrollment records per the College. 8 of 32 students did not have campus reporting completed within the required timeframe. Cause: The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Effect: The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs :None identified. Context: The College disbursed financial aid to approximately 404 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 404 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2022-008. Recommendation: The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Reporting Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education. Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition: The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Cause: The College did not have a process in place to retain reporting documentation. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance: Supplement. Questioned costs: None identified. Context: The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Identification as a repeat finding: Previously reported as finding 2022-006. Recommendation: It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Enrollment Reporting: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268. US Department of Education: Significant Deficiency and Nonmaterial Noncompliance:Criteria or specific requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 11 of 56 program reporting details did not agree to enrollment details from the enrollment records per the College. 7 of 60 campus level reporting details did not have enrollment status that agreed to enrollment records per the College. 8 of 32 students did not have campus reporting completed within the required timeframe. Cause: The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Effect: The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs :None identified. Context: The College disbursed financial aid to approximately 404 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 404 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2022-008. Recommendation: The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Return to Title IV: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education Significant Deficiency and Nonmaterial Noncompliance. Criteria or specific requirements: 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition: During our procedures over Return to Title IV requirements, the following deficiencies were noted: 6 of 31 Return to Title IV calculations were performed outside of the allowable time frame. 3 of 31 withdrawn students did not have a Return to Title IV calculation performed resulting in an overpayment of funds. Cause : The College did not implement procedures to ensure that the Return to Title IV funds were performed accurately and returned in a timely manner. Effect: Without proper monitoring of accuracy and student withdrawal, the College risks noncompliance with the above criteria. Questioned costs: Questioned costs include $4,210 of funds that were not returned to U.S. Department of Education. Context: The college did not perform R2T4 calculations for students under the Pell grant and Direct Loan Programs timely. A nonstatistical sample of 31 R2T4 calculations out of the College’s total population of Return to Title IV testing. Identification as a repeat finding: Previously reported as finding 2022-005. Recommendation: The College should implement procedures to ensure that the student withdrawal calculations are preformed timely and return funds within 30 days from the end of the academic period. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Reporting Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268 US Department of Education. Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 673.3: To participate in the FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the Federal Register. ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) – This electronic report is submitted annually to receive funds for the campus-based programs. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the College. Condition: The College did not retain supporting evidence utilized for reporting critical information within the FISAP. Cause: The College did not have a process in place to retain reporting documentation. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance: Supplement. Questioned costs: None identified. Context: The College lacked evidence to support figures reported in the FISAP. A nonstatistical sample of 4 key line items out of 23 line items in Part VI, Program Summary for Award Year out were selected for reporting testing. Identification as a repeat finding: Previously reported as finding 2022-006. Recommendation: It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Disbursements to or on Behalf of Students: Student Financial Assistance Cluster: – AL 84.007, 84,063 and 84.268. US Department of Education Significant Deficiency and Nonmaterial Noncompliance: Criteria or specific requirements: 34 CFR 668.164(h)(2): Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing over the return of credit balances, the following deficiencies were noted: 27 instances where credit balances were not refunded in the required time frame. 47 instances where refunds were due to students but none were posted in the ledger. 9 instances where the balances refunded to students could not be recalculated. Cause: The College did not comply with Federal disbursement requirements for students under the Pell Grant and Direct Loan programs. Effect: The College is not in compliance with the Federal requirement described in the OMB Compliance Supplement. Questioned costs: None identified. Context : The College contracts with a third-party servicer to perform one or more of the functions associated with disbursing Title IV funds on behalf of the school. A nonstatistical sample of 60 students out of 404 students were selected for disbursement testing. Identification as a repeat finding: Not a previous finding. Recommendation It is recommended the College should establish effective controls and processes to ensure that reporting of FISAP figures are properly supported and any evidence of review is maintained. View of responsible officials and corrective action plan. Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.
Special Tests and Provisions – Enrollment Reporting: Student Financial Assistance Cluster – AL 84.007, 84,063 and 84.268. US Department of Education: Significant Deficiency and Nonmaterial Noncompliance:Criteria or specific requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing over the NSLDS reporting requirements, the following deficiencies were noted: 11 of 56 program reporting details did not agree to enrollment details from the enrollment records per the College. 7 of 60 campus level reporting details did not have enrollment status that agreed to enrollment records per the College. 8 of 32 students did not have campus reporting completed within the required timeframe. Cause: The College did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Effect: The College is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Questioned costs :None identified. Context: The College disbursed financial aid to approximately 404 students that required student enrollment and program enrollment reporting to NSLDS. A nonstatistical sample of 60 students out of 404 students were selected for enrollment reporting testing. Identification as a repeat finding Previously reported as 2022-008. Recommendation: The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of responsible officials and corrective action plan: Management agrees with the finding. Please see separate Corrective Action Plan for procedures to be implemented.