2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-005 – Pell Grant Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Number 84.063; Award Numbers P063P231644 and P063Q231644. Criteria. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule provided by the U.S. Department of Education. Students must be awarded on the basis of a COA comprised of allowable costs assessed to all students carrying the same academic workload. COA must be prorated for students who are attending less than an academic year, or who are less than full‐time in a term based program. Condition. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. Cause. This condition was caused by insufficient review of the COA and EFC data being used by the College in determining the Pell Grant amount for students. Effect. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-005 – Pell Grant Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Number 84.063; Award Numbers P063P231644 and P063Q231644. Criteria. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule provided by the U.S. Department of Education. Students must be awarded on the basis of a COA comprised of allowable costs assessed to all students carrying the same academic workload. COA must be prorated for students who are attending less than an academic year, or who are less than full‐time in a term based program. Condition. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. Cause. This condition was caused by insufficient review of the COA and EFC data being used by the College in determining the Pell Grant amount for students. Effect. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-002 – Return of Title IV (R2T4) Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. Condition. During our testing of six students with Return of Title IV amounts, we noted that the College did not exclude the correct amount of days for scheduled breaks of five days or more in both the fall 2023 and spring 2024 terms, resulting in the incorrect Return of Title IV calculation for all students tested. Cause. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. Effect. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College review the Return of Title IV requirements and implement procedures to ensure the Return of Title IV calculations are using the correct amount of term days and are completed accurately. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-003 – Timeliness of Status Change Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days of the College determining the change or on the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission report if the next scheduled enrollment roster transmission is within 60 days of the College determining the status change. Regulations require the status to include an accurate effective date. Condition. It was noted during our testing of 13 students with status changes, two instances of late reporting of status changes. Both of these instances were fall graduates whose status change was not reported within the required timeframe. Cause. The College does not have policies and procedures in place to ensure a student's status change is reported to the NSLDS in a timely manner. Effect. As a result of this condition, the NSLDS had incorrect records of the enrollment status of students. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College reviews the status change reporting requirements and implement procedures to ensure that the status changes are being reported to the NSLDS in a timely manner. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-004 – Fiscal Operations Report and Application to Participate (FISAP) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A232049, P033A232049, P063P231644, and P268K241644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. The College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-005 – Pell Grant Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Number 84.063; Award Numbers P063P231644 and P063Q231644. Criteria. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule provided by the U.S. Department of Education. Students must be awarded on the basis of a COA comprised of allowable costs assessed to all students carrying the same academic workload. COA must be prorated for students who are attending less than an academic year, or who are less than full‐time in a term based program. Condition. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. Cause. This condition was caused by insufficient review of the COA and EFC data being used by the College in determining the Pell Grant amount for students. Effect. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-005 – Pell Grant Calculation. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Number 84.063; Award Numbers P063P231644 and P063Q231644. Criteria. The Uniform Guidance states that the College must determine the maximum scheduled award a student would receive based on their Expected Family Contribution (EFC) and Cost of Attendance (COA) using the payment schedule provided by the U.S. Department of Education. Students must be awarded on the basis of a COA comprised of allowable costs assessed to all students carrying the same academic workload. COA must be prorated for students who are attending less than an academic year, or who are less than full‐time in a term based program. Condition. One student out of the twenty five Pell grants tested was found to be under awarded based on the enrollment status and cost of attendance. Cause. This condition was caused by insufficient review of the COA and EFC data being used by the College in determining the Pell Grant amount for students. Effect. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement procedures to ensure the COA and EFC used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-006 – Common Origination and Disbursement (COD) Reporting. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.063 and 84.268; Award Numbers P063P231644, P063Q231644 and P268K241644. Criteria. The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition. During our testing of COD reporting, we identified one of 40 disbursements was not reported to COD within 15 days of the disbursement date. Cause. The College did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner. Effect. A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College evaluate and enhance its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
2024-007 – Procurement, Suspension and Debarment Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. COVID-19 - Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027, All Award Numbers. Criteria. 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition. During our testing of disbursements, it was noted that the College did not follow their procurement policy for purchases over the micro purchase threshold and there is no procedure in place to determine whether vendors are suspended or debarred. Cause. The College did not have a procedure in place to require documentation be maintained that the search for suspension and department associated with procurement transactions in excess of the $25,000 threshold had been performed prior to procurement. Effect. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that the College implement a policy over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable, and to follow their procurement policy when entering into purchases greater than the micro purchase threshold. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.