2024 – 001: Return of Title IV Funds
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 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: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date
Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement.
Questioned costs: None
Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals
Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement.
Repeat finding: Yes; prior year finding number was 2023-002.
Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024 – 001: Return of Title IV Funds
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 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: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date
Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement.
Questioned costs: None
Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals
Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement.
Repeat finding: Yes; prior year finding number was 2023-002.
Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024 – 001: Return of Title IV Funds
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 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: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date
Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement.
Questioned costs: None
Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals
Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement.
Repeat finding: Yes; prior year finding number was 2023-002.
Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024 – 001: Return of Title IV Funds
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 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: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date
Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement.
Questioned costs: None
Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals
Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement.
Repeat finding: Yes; prior year finding number was 2023-002.
Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs.
Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts.
Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs.
Questioned costs: $19,435
Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students.
Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435.
Repeat finding: No
Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Number: 84.007, 84.033, 84.063, 84.268
Federal Award Identification Number and Year: Various
Award Period: July 1, 2023, to June 30, 2024
Type of Finding:
• Compliance, Other Matter
• Material Weakness in Internal Control Over Compliance
Criteria or specific requirement: Per Uniform Guidance 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates.
Questioned costs: None
Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat finding: Yes; prior year finding number 2023-003
Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
View of responsible official: Management agrees with the finding and has already implemented a corrective plan.