Audit 343993

FY End
2024-05-31
Total Expended
$24.65M
Findings
2
Programs
5
Year: 2024 Accepted: 2025-02-26
Auditor: Rsm US LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
524562 2024-001 Significant Deficiency - C
1101004 2024-001 Significant Deficiency - C

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $22.73M Yes 1
84.063 Federal Pell Grant Program $1.04M Yes 0
84.031 Developing Hispanic-Serving Institutions (hsi) Program $700,770 Yes 0
84.033 Federal Work-Study Program $104,090 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $69,800 Yes 0

Contacts

Name Title Type
SHHSN59W3LV3 Theresa Cowan Auditee
3177556905 Craig Wories Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are recognized on the accrual basis of accounting. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College elected to either use an award specific rate, or did not allocate indirect costs. The accompanying schedule of expenditures of federal awards (the “Schedule”) includes the federal award activity of Pacific Oaks Education Corporation (the College) under programs of the federal government for the year ended May 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the College. No funds were identified as having been provided to subrecipients by the College, and accordingly, no funds identified in the Schedule are attributable to subrecipient entities. There were no federal awards expended for non-cash assistance or insurance at year-end.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are recognized on the accrual basis of accounting. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College elected to either use an award specific rate, or did not allocate indirect costs. Expenditures reported on the Schedule are recognized on the accrual basis of accounting. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement.
Title: Note 3. Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule are recognized on the accrual basis of accounting. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College elected to either use an award specific rate, or did not allocate indirect costs. The College has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Note 4. Federal Student Loan Program Accounting Policies: Expenditures reported on the Schedule are recognized on the accrual basis of accounting. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College elected to either use an award specific rate, or did not allocate indirect costs. During the fiscal year ended May 31, 2024, the College issued new loans to students under the Federal Direct Student Loan Program (FDLP). The loan program includes subsidized and unsubsidized Stafford Loans, Parent PLUS Loans, and PLUS Loans for graduate and professional students. The value of loans issued for the FDLP is based on disbursed amounts. The loan amounts issued during the year are disclosed on the Schedule. The College is responsible only for the performance of certain administrative duties with respect to the federally guaranteed student loan programs and, accordingly, balances and transactions relating to these loan programs are not included in the College’s financial statements. Therefore, it is not practicable to determine the balance of loans outstanding to students and former students of the College at May 31, 2024.

Finding Details

Finding 2024-001: Excess Cash – Student Financial Aid Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $22,734,225 Questioned Costs: None Criteria: Uniform Guidance for the Department of Education (34 CFR 668.166) states the Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution: (1) received those funds from the Secretary; or (2) deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from awards adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure excess cash is properly handled. Condition: Pacific Oaks Education Corporation (the College) had one instance of excess cash for the Federal Direct Student Loan program. During our cash management testing, we identified the College had excess cash for the Direct Loan program ranging from $1,335,590 to $4,774,182 for the period from September 6, 2023 to September 13, 2023. For that period, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within the three business-day period. Cause: College officials explained that the excess cash resulted from the College’s practice of drawing funds early to ensure timely disbursement of stipends to students. The drawdown occurred prior to completing the reconciliation of the award amounts. As a result, while the funds were drawn, they were not posted to the students' ledgers within the required three-day period, leading to the excess cash being held for a longer duration than allowed. Effect: Excess cash is noncompliance with Federal regulations and could result in heightened monitoring by the U.S. Department of Education. Questioned Costs: None Context: For the period of September 6, 2023 to September 13, 2023, the College had excess cash in the amount ranging from $1,335,590 to $4,774,182. The College held excess cash for a period of 5 business days. Repeat Finding: No. Recommendation: We recommend the College strengthen internal controls around cash management to prevent or timely correct excess cash instances. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Finding 2024-001: Excess Cash – Student Financial Aid Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $22,734,225 Questioned Costs: None Criteria: Uniform Guidance for the Department of Education (34 CFR 668.166) states the Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution: (1) received those funds from the Secretary; or (2) deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from awards adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure excess cash is properly handled. Condition: Pacific Oaks Education Corporation (the College) had one instance of excess cash for the Federal Direct Student Loan program. During our cash management testing, we identified the College had excess cash for the Direct Loan program ranging from $1,335,590 to $4,774,182 for the period from September 6, 2023 to September 13, 2023. For that period, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within the three business-day period. Cause: College officials explained that the excess cash resulted from the College’s practice of drawing funds early to ensure timely disbursement of stipends to students. The drawdown occurred prior to completing the reconciliation of the award amounts. As a result, while the funds were drawn, they were not posted to the students' ledgers within the required three-day period, leading to the excess cash being held for a longer duration than allowed. Effect: Excess cash is noncompliance with Federal regulations and could result in heightened monitoring by the U.S. Department of Education. Questioned Costs: None Context: For the period of September 6, 2023 to September 13, 2023, the College had excess cash in the amount ranging from $1,335,590 to $4,774,182. The College held excess cash for a period of 5 business days. Repeat Finding: No. Recommendation: We recommend the College strengthen internal controls around cash management to prevent or timely correct excess cash instances. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.