Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant
Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster
Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for
reporting enrollment details under the Pell grant and other programs. Institutions must update the
Enrollment Reporting Roster for changes in student status, report the date the enrollment status
was effective, enter the new anticipated completion date and submit the changes electronically
through the batch method or the National Student Loan Data System (NSLDS) website. Institutions
are responsible for timely reporting, whether they report directly or via a third-party servicer. These
changes include reductions or increases in attendance levels, withdrawals, graduations or approved
leaves-of-absence.
Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was
not reported within the required 60-day time frame.
Cause: Unofficial withdraws from the College are not determined until after the end of the
semester. Based on current procedures, these student status changes were not included in the last
report of the semester and the next reporting submission was not submitted timely.
Effect: The College did not report the student enrollment status change in a timely manner.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures related to
enrollment reporting requirements to comply with the regulations.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant
Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster
Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for
reporting enrollment details under the Pell grant and other programs. Institutions must update the
Enrollment Reporting Roster for changes in student status, report the date the enrollment status
was effective, enter the new anticipated completion date and submit the changes electronically
through the batch method or the National Student Loan Data System (NSLDS) website. Institutions
are responsible for timely reporting, whether they report directly or via a third-party servicer. These
changes include reductions or increases in attendance levels, withdrawals, graduations or approved
leaves-of-absence.
Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was
not reported within the required 60-day time frame.
Cause: Unofficial withdraws from the College are not determined until after the end of the
semester. Based on current procedures, these student status changes were not included in the last
report of the semester and the next reporting submission was not submitted timely.
Effect: The College did not report the student enrollment status change in a timely manner.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures related to
enrollment reporting requirements to comply with the regulations.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant
Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster
Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for
reporting enrollment details under the Pell grant and other programs. Institutions must update the
Enrollment Reporting Roster for changes in student status, report the date the enrollment status
was effective, enter the new anticipated completion date and submit the changes electronically
through the batch method or the National Student Loan Data System (NSLDS) website. Institutions
are responsible for timely reporting, whether they report directly or via a third-party servicer. These
changes include reductions or increases in attendance levels, withdrawals, graduations or approved
leaves-of-absence.
Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was
not reported within the required 60-day time frame.
Cause: Unofficial withdraws from the College are not determined until after the end of the
semester. Based on current procedures, these student status changes were not included in the last
report of the semester and the next reporting submission was not submitted timely.
Effect: The College did not report the student enrollment status change in a timely manner.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures related to
enrollment reporting requirements to comply with the regulations.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-007 – Allowable Costs & Period of Performance (Material Weakness and
Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid (Title III), Assistance Listing No. 84.031
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements. In addition, a non-federal entity
may charge only allowable costs incurred during the approved budget period of a federal award’s
period of performance and any costs incurred before the federal awarding agency or pass-through
entity made the federal award that were authorized by the federal awarding agency or pass-through
entity (2 CFR sections 200.308, 200.309, and 200.403(h)).
Condition: We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements
charged to the grant. Of the 25 non-payroll, 4 were missing an approval by the Director of Title III
Programs and 4 costs were not in the applicable budgets. In addition, 2 were charged to a fund
code for a grant period that ended September 30, 2023.
There were 44 pay checks tested in the sample of 25; of those 44, 31 exceptions were noted as
having an issue around the approved pay rate documentation. In 9 instances, there was no
documented approved pay rate, only support provided was a local salary schedule for multiple
positions for 6 of the exceptions. In 15 instances, there was no approval for salary to be charged to
the grant number and documentation showed unrestricted, a different account or offer letter had no
Title III documentation. In 7 instances, the approved pay rate did not agree to actual paycheck
report.
Cause: The College did not obtain proper approval by the Director of the program, expenses did
not fit into the grant budget line items, approved pay rates were not properly documented and the
College continued to use funds after the grant period ended based on verbal instruction.
Effect: The College’s grant disbursements were not properly approved.
Questioned Costs: $35,461
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll and non-payroll grant disbursements to ensure controls are functioning and compliant with
federal regulations
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-008 – Cash Management (Material Weakness and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031Criteria: 2 CFR Part 200.305 establishes the methods of receiving payment from the federal
agency. The College uses the reimbursement method to receive Title III funds. The non-federal
entity is also required to design and implement internal controls over the cash management
process.
Condition: We selected 5 drawdowns for reimbursement made during the year for testing. For 4
drawdowns, there was no documentation of a review of the calculation of the amount to draw or
approval to draw down the funds.
Cause: The College did not have a review and approval process in place for 9 months of the fiscal
year.
Effect: The College’s grant reimbursements were not properly approved.
Questioned Costs: None reported
Recommendation: We recommend the College strengthen its policies and procedures over cash
management to ensure controls are properly implemented and working effectively.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-009 – Reporting (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031
Criteria: 2 CFR Part 200.328 & 329 establish reporting requirements for non-federal entities that
include timely and accurate reporting. Non-federal entities are also required to establish controls
over the reporting process to ensure compliance with reporting requirements.
Condition: We selected 2 annual reports submitted during the year to test for controls and
compliance. No documentation of review or approval of the reports was available.
Cause: The College did not retain documentation of a review and approval of Title III reports
submitted.
Effect: The College did not have appropriate documentation.
Questioned Costs: None reported
Recommendation: We recommend the College strengthen its policies and procedures over the
grant reporting process to ensure controls are properly implemented and working effectively.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-010 – Procurement (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031
Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This
includes different requirements based on the amount of purchases made from the vendor during the
year.
Condition: We selected 7 vendors for procurement testing. Of those 7, it was noted that one
vendor was paid over the micro-purchase threshold and therefore should have obtained price or
rate quotes.
Cause: The College did not obtain price or rate quotes for this vendor that had provided services
for several years.
Effect: The College did not have appropriate documentation.
Questioned Costs: $24,250
Recommendation: We recommend the College strengthen its policies and procedures over
procurement to ensure vendors in the small purchase category are properly procured.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-011 – Equipment Management (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031
Criteria: 2 CFR Section 200.313(d)(2) establishes the requirement that a physical inventory of
property must be taken and the results reconciled with the property records at least every 2 years.
Condition: Documentation of a physical inventory performed college-wide was not available.
Cause: The College did not perform a physical inventory of assets purchased with federal funds in
the last 2 years.
Effect: The College did not have appropriate documentation that a physical inventory was
performed.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures over
equipment management to ensure a physical inventory is performed every 2 years, at a minimum. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant
Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster
Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for
reporting enrollment details under the Pell grant and other programs. Institutions must update the
Enrollment Reporting Roster for changes in student status, report the date the enrollment status
was effective, enter the new anticipated completion date and submit the changes electronically
through the batch method or the National Student Loan Data System (NSLDS) website. Institutions
are responsible for timely reporting, whether they report directly or via a third-party servicer. These
changes include reductions or increases in attendance levels, withdrawals, graduations or approved
leaves-of-absence.
Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was
not reported within the required 60-day time frame.
Cause: Unofficial withdraws from the College are not determined until after the end of the
semester. Based on current procedures, these student status changes were not included in the last
report of the semester and the next reporting submission was not submitted timely.
Effect: The College did not report the student enrollment status change in a timely manner.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures related to
enrollment reporting requirements to comply with the regulations.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant
Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster
Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for
reporting enrollment details under the Pell grant and other programs. Institutions must update the
Enrollment Reporting Roster for changes in student status, report the date the enrollment status
was effective, enter the new anticipated completion date and submit the changes electronically
through the batch method or the National Student Loan Data System (NSLDS) website. Institutions
are responsible for timely reporting, whether they report directly or via a third-party servicer. These
changes include reductions or increases in attendance levels, withdrawals, graduations or approved
leaves-of-absence.
Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was
not reported within the required 60-day time frame.
Cause: Unofficial withdraws from the College are not determined until after the end of the
semester. Based on current procedures, these student status changes were not included in the last
report of the semester and the next reporting submission was not submitted timely.
Effect: The College did not report the student enrollment status change in a timely manner.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures related to
enrollment reporting requirements to comply with the regulations.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-012 – Special Tests and Provisions- Enrollment Reporting (Significant
Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education Student Financial Aid Cluster
Criteria: The NSLDS Enrollment Reporting Guide provides requirements and guidance for
reporting enrollment details under the Pell grant and other programs. Institutions must update the
Enrollment Reporting Roster for changes in student status, report the date the enrollment status
was effective, enter the new anticipated completion date and submit the changes electronically
through the batch method or the National Student Loan Data System (NSLDS) website. Institutions
are responsible for timely reporting, whether they report directly or via a third-party servicer. These
changes include reductions or increases in attendance levels, withdrawals, graduations or approved
leaves-of-absence.
Condition: We tested a sample of 25 withdrawn students. In 5 instances, the change in status was
not reported within the required 60-day time frame.
Cause: Unofficial withdraws from the College are not determined until after the end of the
semester. Based on current procedures, these student status changes were not included in the last
report of the semester and the next reporting submission was not submitted timely.
Effect: The College did not report the student enrollment status change in a timely manner.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures related to
enrollment reporting requirements to comply with the regulations.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-007 – Allowable Costs & Period of Performance (Material Weakness and
Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid (Title III), Assistance Listing No. 84.031
Criteria: 2 CFR Part 200 Subpart E establishes cost principles to apply in determining costs under
federal awards. Non-federal entities are also required to establish controls over the disbursement
process to ensure compliance with allowable cost requirements. In addition, a non-federal entity
may charge only allowable costs incurred during the approved budget period of a federal award’s
period of performance and any costs incurred before the federal awarding agency or pass-through
entity made the federal award that were authorized by the federal awarding agency or pass-through
entity (2 CFR sections 200.308, 200.309, and 200.403(h)).
Condition: We selected a sample of 25 non-payroll disbursements and 25 payroll disbursements
charged to the grant. Of the 25 non-payroll, 4 were missing an approval by the Director of Title III
Programs and 4 costs were not in the applicable budgets. In addition, 2 were charged to a fund
code for a grant period that ended September 30, 2023.
There were 44 pay checks tested in the sample of 25; of those 44, 31 exceptions were noted as
having an issue around the approved pay rate documentation. In 9 instances, there was no
documented approved pay rate, only support provided was a local salary schedule for multiple
positions for 6 of the exceptions. In 15 instances, there was no approval for salary to be charged to
the grant number and documentation showed unrestricted, a different account or offer letter had no
Title III documentation. In 7 instances, the approved pay rate did not agree to actual paycheck
report.
Cause: The College did not obtain proper approval by the Director of the program, expenses did
not fit into the grant budget line items, approved pay rates were not properly documented and the
College continued to use funds after the grant period ended based on verbal instruction.
Effect: The College’s grant disbursements were not properly approved.
Questioned Costs: $35,461
Recommendation: We recommend the College strengthen its policies and procedures surrounding
payroll and non-payroll grant disbursements to ensure controls are functioning and compliant with
federal regulations
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-008 – Cash Management (Material Weakness and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031Criteria: 2 CFR Part 200.305 establishes the methods of receiving payment from the federal
agency. The College uses the reimbursement method to receive Title III funds. The non-federal
entity is also required to design and implement internal controls over the cash management
process.
Condition: We selected 5 drawdowns for reimbursement made during the year for testing. For 4
drawdowns, there was no documentation of a review of the calculation of the amount to draw or
approval to draw down the funds.
Cause: The College did not have a review and approval process in place for 9 months of the fiscal
year.
Effect: The College’s grant reimbursements were not properly approved.
Questioned Costs: None reported
Recommendation: We recommend the College strengthen its policies and procedures over cash
management to ensure controls are properly implemented and working effectively.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-009 – Reporting (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031
Criteria: 2 CFR Part 200.328 & 329 establish reporting requirements for non-federal entities that
include timely and accurate reporting. Non-federal entities are also required to establish controls
over the reporting process to ensure compliance with reporting requirements.
Condition: We selected 2 annual reports submitted during the year to test for controls and
compliance. No documentation of review or approval of the reports was available.
Cause: The College did not retain documentation of a review and approval of Title III reports
submitted.
Effect: The College did not have appropriate documentation.
Questioned Costs: None reported
Recommendation: We recommend the College strengthen its policies and procedures over the
grant reporting process to ensure controls are properly implemented and working effectively.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-010 – Procurement (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031
Criteria: 2 CFR 200.317-327 establishes procurement standards for non-federal entities. This
includes different requirements based on the amount of purchases made from the vendor during the
year.
Condition: We selected 7 vendors for procurement testing. Of those 7, it was noted that one
vendor was paid over the micro-purchase threshold and therefore should have obtained price or
rate quotes.
Cause: The College did not obtain price or rate quotes for this vendor that had provided services
for several years.
Effect: The College did not have appropriate documentation.
Questioned Costs: $24,250
Recommendation: We recommend the College strengthen its policies and procedures over
procurement to ensure vendors in the small purchase category are properly procured.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.
Finding 2024-011 – Equipment Management (Significant Deficiency and Noncompliance)
Information on the Federal Program: U.S. Department of Education, Higher Education-
Institutional Aid, Assistance Listing No. 84.031
Criteria: 2 CFR Section 200.313(d)(2) establishes the requirement that a physical inventory of
property must be taken and the results reconciled with the property records at least every 2 years.
Condition: Documentation of a physical inventory performed college-wide was not available.
Cause: The College did not perform a physical inventory of assets purchased with federal funds in
the last 2 years.
Effect: The College did not have appropriate documentation that a physical inventory was
performed.
Questioned Costs: None
Recommendation: We recommend the College strengthen its policies and procedures over
equipment management to ensure a physical inventory is performed every 2 years, at a minimum. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.