Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s Estimated Family Contribution (EFC) and the enrollment status of the student. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: The District awarded an incorrect Pell award amount for this student one out of the 40 students tested, which is a statistically valid sample.
Questioned costs: $2,185
Context: The District awarded $10,538,170 in Pell Grant during the year.
Cause: The overpayment of Pell Grant was due to the District not using information updated by the student for EFC.
Effect: One student was over-awarded Pell Grant funds.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 11 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. The value of the sample tested was $6,689, and the portion of the unearned aid not returned timely was $3,683.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: Yes, see Finding 2023-002.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted one instance of change in status not reported timely during the Fall 2023 semester.
Questioned Costs: None.
Context: One exception was noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District revised its enrollment reporting controls after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. However, prior to this implementation the internal controls that were in place did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: Yes, see Finding 2023-003.
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: $66,864
Context: The District disbursed $12,283,383 in Title IV awards during fiscal year 2023-24. There were a total of 75 checks outside the 240-day timeframe, totaling $66,864.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2023-004.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria: In accordance with 2 CFR 200.303, the District must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, the Code of Federal Regulations, 34 CFR 668.164 states that a school must provide to the Department of Education an up-to-date URL for the contract publication in a centralized database accessible to the public.
Condition: During our testing, we noted the District did not provide an up-to-date URL to the Department of Education.
Questioned Costs: None.
Context: The District did not provide an up-to-date URL to the Department of Education within the current fiscal year.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations.
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: No.
Recommendation: We recommend the District re-evaluate their procedures for providing up-to-date URL information to the Department of Education.
Views of responsible officials: Management concurs with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s Estimated Family Contribution (EFC) and the enrollment status of the student. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: The District awarded an incorrect Pell award amount for this student one out of the 40 students tested, which is a statistically valid sample.
Questioned costs: $2,185
Context: The District awarded $10,538,170 in Pell Grant during the year.
Cause: The overpayment of Pell Grant was due to the District not using information updated by the student for EFC.
Effect: One student was over-awarded Pell Grant funds.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts.
Views of responsible officials: Management concurs with the finding.