Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary.
Condition/context: Direct Loan reconciliations were not completed for six months of the fiscal year - the months of January 2024 through June 2024. Additionally, support for Direct Loan reconciliations that had been completed was not maintained during the year.
Cause: During the transition of Student Financial Aid Directors during the year, there was an issue in which the SAIG was unavailable to the Financial Aid Director due to previous access at another institution.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, if not completed on a regular basis, the school is at risk of not meeting disbursement reporting and excess cash deadlines.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations that includes process and procedures in place to complete monthly reconciliations when the main point of contact or access to SAIG and COD is not available. Additionally, the College should develop procedures and requirements to maintain monthly Direct Loan reconciliations and associated support.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred no later than 45 days after the institution determines that the student withdrew.
Condition/context: Of the 12 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew.
Cause: The College did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and that unearned Title IV aid was returned to the U.S. Department of Education timely.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary.
Condition/context: Of the 16 students selected for testing:
• Two students’ withdrawn status was not reported to NSLDS.
• Three students were not reported to NSLDS with an accurate withdrawal date.
• One student’s program length was improperly reported as 2.5 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: Yes - see finding 2023-003.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned correction actions: Management concurs with the finding. See Exhibit I.
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement.
Condition/context: Of the 25 students selected for Pell reporting testing, 19 students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement.
Cause: During the transition of Financial Aid Directors, an error occurred in the assignment of the Primary Destination Point Administrator that resulted in an inability to import and export from Colleague to Student Aid Internet Gateway (SAIG) for COD and National Student Loan Data System (NSLDS) reporting. During this time, the College was unable to export disbursement information in a timely manner, which caused a delay in the COD processing of disbursement records.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary.
Condition/context: Of the 16 students selected for testing:
• Two students’ withdrawn status was not reported to NSLDS.
• Three students were not reported to NSLDS with an accurate withdrawal date.
• One student’s program length was improperly reported as 2.5 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: Yes - see finding 2023-003.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned correction actions: Management concurs with the finding. See Exhibit I.
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Per the Fiscal Operations Report for 2022-23 and Application to Participate for 2024-25 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D.
Condition/context: Tuition and fees for the award year July 1, 2022 to June 30, 2023 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $68,880,369. The correct amount was $6,880,369.
Cause: Human error.
Effect: If Western Wyoming Community College (the College) fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the U.S. Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough system of review of the FISAP to ensure that accurate information is reported.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Per the Fiscal Operations Report for 2022-23 and Application to Participate for 2024-25 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D.
Condition/context: Tuition and fees for the award year July 1, 2022 to June 30, 2023 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $68,880,369. The correct amount was $6,880,369.
Cause: Human error.
Effect: If Western Wyoming Community College (the College) fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the U.S. Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough system of review of the FISAP to ensure that accurate information is reported.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary.
Condition/context: Direct Loan reconciliations were not completed for six months of the fiscal year - the months of January 2024 through June 2024. Additionally, support for Direct Loan reconciliations that had been completed was not maintained during the year.
Cause: During the transition of Student Financial Aid Directors during the year, there was an issue in which the SAIG was unavailable to the Financial Aid Director due to previous access at another institution.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, if not completed on a regular basis, the school is at risk of not meeting disbursement reporting and excess cash deadlines.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations that includes process and procedures in place to complete monthly reconciliations when the main point of contact or access to SAIG and COD is not available. Additionally, the College should develop procedures and requirements to maintain monthly Direct Loan reconciliations and associated support.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred no later than 45 days after the institution determines that the student withdrew.
Condition/context: Of the 12 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew.
Cause: The College did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and that unearned Title IV aid was returned to the U.S. Department of Education timely.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary.
Condition/context: Of the 16 students selected for testing:
• Two students’ withdrawn status was not reported to NSLDS.
• Three students were not reported to NSLDS with an accurate withdrawal date.
• One student’s program length was improperly reported as 2.5 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: Yes - see finding 2023-003.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned correction actions: Management concurs with the finding. See Exhibit I.
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement.
Condition/context: Of the 25 students selected for Pell reporting testing, 19 students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement.
Cause: During the transition of Financial Aid Directors, an error occurred in the assignment of the Primary Destination Point Administrator that resulted in an inability to import and export from Colleague to Student Aid Internet Gateway (SAIG) for COD and National Student Loan Data System (NSLDS) reporting. During this time, the College was unable to export disbursement information in a timely manner, which caused a delay in the COD processing of disbursement records.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary.
Condition/context: Of the 16 students selected for testing:
• Two students’ withdrawn status was not reported to NSLDS.
• Three students were not reported to NSLDS with an accurate withdrawal date.
• One student’s program length was improperly reported as 2.5 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period.
Questioned costs: None.
Identification as a repeat finding: Yes - see finding 2023-003.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials and planned correction actions: Management concurs with the finding. See Exhibit I.
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Per the Fiscal Operations Report for 2022-23 and Application to Participate for 2024-25 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D.
Condition/context: Tuition and fees for the award year July 1, 2022 to June 30, 2023 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $68,880,369. The correct amount was $6,880,369.
Cause: Human error.
Effect: If Western Wyoming Community College (the College) fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the U.S. Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough system of review of the FISAP to ensure that accurate information is reported.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Per the Fiscal Operations Report for 2022-23 and Application to Participate for 2024-25 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D.
Condition/context: Tuition and fees for the award year July 1, 2022 to June 30, 2023 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $68,880,369. The correct amount was $6,880,369.
Cause: Human error.
Effect: If Western Wyoming Community College (the College) fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339.
Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the U.S. Department of Education. The school may be required to return funds to which it is not entitled.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a thorough system of review of the FISAP to ensure that accurate information is reported.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.