Audit 336039

FY End
2024-06-30
Total Expended
$13.50M
Findings
8
Programs
6
Year: 2024 Accepted: 2025-01-06
Auditor: Capincrouse LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
517857 2024-002 Material Weakness Yes N
517858 2024-002 Material Weakness Yes N
517859 2024-003 Material Weakness - N
517860 2024-003 Material Weakness - N
1094299 2024-002 Material Weakness Yes N
1094300 2024-002 Material Weakness Yes N
1094301 2024-003 Material Weakness - N
1094302 2024-003 Material Weakness - N

Contacts

Name Title Type
MAKYDTN5CLM8 Eric Froistad Auditee
8007772227 Dan Campbell, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO CONSOLIDATED FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Columbia International University and Subsidiaries (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. See the Notes to the SEFA for chart/table
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Columbia International University and Subsidiaries (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.
Title: INSTITUTION ELIGIBILITY LIMITATIONS IN ACCORDANCE WITH 34 CFR 600.7(a)1 Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Columbia International University and Subsidiaries (University) under programs of the federal government for the year ended June 30, 2024. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the University is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. To maintain institutional eligibility to participate in the Department of Education’s Title IV financial aid programs, the University is required to comply with 34 CFR 600.7(a)1 which limits the number of correspondence courses, the number of students enrolled in correspondence courses, the number of incarcerated students enrolled and the number of students enrolled without a high school diploma or recognized equivalent. As part of the audit procedures, compliance with these limitations was tested. No non-compliance with the requirements was noted.

Finding Details

Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $134 Context: Out of 20 students tested, 4 students had late returns of $3,784 in Federal Direct Loans (FDL) and $2,777 in Pell ranging from 6 to 23 days late. Additionally, 6 students had incorrect R2T4 calculations. One student had an incorrect last date of attendance (LDA) used in the calculation causing an under-award of Pell ($55) in the student’s post-withdrawal disbursement (PWD). Four students had incorrect end dates used in their calculations, however it only impacted two students causing over-returns of Pell ($19). One student had incorrect total days in the payment period used in the calculation causing an under-return of federal direct loans ($134). These were corrected during the audit. Cause: There was turnover in the role of Associate Director for Online Studies midway through the academic year. Effect: Return of Title IV funds were not performed accurately and timely. Identification as repeat finding, if applicable: 2023-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend the University review calendar set-ups used for R2T4 calculations. Lastly, we recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $134 Context: Out of 20 students tested, 4 students had late returns of $3,784 in Federal Direct Loans (FDL) and $2,777 in Pell ranging from 6 to 23 days late. Additionally, 6 students had incorrect R2T4 calculations. One student had an incorrect last date of attendance (LDA) used in the calculation causing an under-award of Pell ($55) in the student’s post-withdrawal disbursement (PWD). Four students had incorrect end dates used in their calculations, however it only impacted two students causing over-returns of Pell ($19). One student had incorrect total days in the payment period used in the calculation causing an under-return of federal direct loans ($134). These were corrected during the audit. Cause: There was turnover in the role of Associate Director for Online Studies midway through the academic year. Effect: Return of Title IV funds were not performed accurately and timely. Identification as repeat finding, if applicable: 2023-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend the University review calendar set-ups used for R2T4 calculations. Lastly, we recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
NSLDS Reporting Errors Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Students’ reported enrollment statuses were not always updated accurately and timely to NSLDS. Criteria: 34 CFR 690.83(b)(2), 34 CFR 685.309 Questioned Costs: $0 Context: 11 out of 75 students tested had reporting errors for NSLDS enrollment. These were corrected during the audit. Cause: Turnover in the Registrar’s office and system issues caused by transitioning online undergraduate students from non-standard terms to traditional terms. Effect: Delays and errors in enrollment reporting to NSLDS. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a spot check for NSLDS enrollment reporting periodically during the academic year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
NSLDS Reporting Errors Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Students’ reported enrollment statuses were not always updated accurately and timely to NSLDS. Criteria: 34 CFR 690.83(b)(2), 34 CFR 685.309 Questioned Costs: $0 Context: 11 out of 75 students tested had reporting errors for NSLDS enrollment. These were corrected during the audit. Cause: Turnover in the Registrar’s office and system issues caused by transitioning online undergraduate students from non-standard terms to traditional terms. Effect: Delays and errors in enrollment reporting to NSLDS. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a spot check for NSLDS enrollment reporting periodically during the academic year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $134 Context: Out of 20 students tested, 4 students had late returns of $3,784 in Federal Direct Loans (FDL) and $2,777 in Pell ranging from 6 to 23 days late. Additionally, 6 students had incorrect R2T4 calculations. One student had an incorrect last date of attendance (LDA) used in the calculation causing an under-award of Pell ($55) in the student’s post-withdrawal disbursement (PWD). Four students had incorrect end dates used in their calculations, however it only impacted two students causing over-returns of Pell ($19). One student had incorrect total days in the payment period used in the calculation causing an under-return of federal direct loans ($134). These were corrected during the audit. Cause: There was turnover in the role of Associate Director for Online Studies midway through the academic year. Effect: Return of Title IV funds were not performed accurately and timely. Identification as repeat finding, if applicable: 2023-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend the University review calendar set-ups used for R2T4 calculations. Lastly, we recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely and return calculations were not done correctly consistently. Criteria: 34 CFR 668.22 Questioned Costs: $134 Context: Out of 20 students tested, 4 students had late returns of $3,784 in Federal Direct Loans (FDL) and $2,777 in Pell ranging from 6 to 23 days late. Additionally, 6 students had incorrect R2T4 calculations. One student had an incorrect last date of attendance (LDA) used in the calculation causing an under-award of Pell ($55) in the student’s post-withdrawal disbursement (PWD). Four students had incorrect end dates used in their calculations, however it only impacted two students causing over-returns of Pell ($19). One student had incorrect total days in the payment period used in the calculation causing an under-return of federal direct loans ($134). These were corrected during the audit. Cause: There was turnover in the role of Associate Director for Online Studies midway through the academic year. Effect: Return of Title IV funds were not performed accurately and timely. Identification as repeat finding, if applicable: 2023-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third-party administrator to ensure that R2T4’s are completed timely when students cease attendance during the term. We also recommend the University review calendar set-ups used for R2T4 calculations. Lastly, we recommend additional staff be allocated to the withdrawal process due to the high population of students (approx. 10%) who withdraw officially or unofficially. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
NSLDS Reporting Errors Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Students’ reported enrollment statuses were not always updated accurately and timely to NSLDS. Criteria: 34 CFR 690.83(b)(2), 34 CFR 685.309 Questioned Costs: $0 Context: 11 out of 75 students tested had reporting errors for NSLDS enrollment. These were corrected during the audit. Cause: Turnover in the Registrar’s office and system issues caused by transitioning online undergraduate students from non-standard terms to traditional terms. Effect: Delays and errors in enrollment reporting to NSLDS. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a spot check for NSLDS enrollment reporting periodically during the academic year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
NSLDS Reporting Errors Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: Students’ reported enrollment statuses were not always updated accurately and timely to NSLDS. Criteria: 34 CFR 690.83(b)(2), 34 CFR 685.309 Questioned Costs: $0 Context: 11 out of 75 students tested had reporting errors for NSLDS enrollment. These were corrected during the audit. Cause: Turnover in the Registrar’s office and system issues caused by transitioning online undergraduate students from non-standard terms to traditional terms. Effect: Delays and errors in enrollment reporting to NSLDS. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University implement a spot check for NSLDS enrollment reporting periodically during the academic year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.