2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.163, 668.166 notes, “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 received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award 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.(34 CFR 668.163, 668.166)”.
Condition: During our testing of thirty-seven draw downs, we noted four individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $25,712
Cause and Effect: The condition was caused by changes in students enrollment statuses that were not caught in their reconciliation process which resulted in them requesting funds from the Common Origination and Disbursement (COD) system although they were no longer eligible for disbursements in the Spring semester due to graduating, withdrawing, or other circumstances. As a result, the College is retaining federal monies longer than allowed.
Recommendation: We recommend that the College implement procedures and cash controls to avoid having excess cash.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.163, 668.166 notes, “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 received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award 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.(34 CFR 668.163, 668.166)”.
Condition: During our testing of thirty-seven draw downs, we noted four individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $25,712
Cause and Effect: The condition was caused by changes in students enrollment statuses that were not caught in their reconciliation process which resulted in them requesting funds from the Common Origination and Disbursement (COD) system although they were no longer eligible for disbursements in the Spring semester due to graduating, withdrawing, or other circumstances. As a result, the College is retaining federal monies longer than allowed.
Recommendation: We recommend that the College implement procedures and cash controls to avoid having excess cash.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance requirement and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Effect: The College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.”
Condition: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003.
Statistical sampling was not used in making sample selections.
Questioned Costs: $809
Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-004 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.
Condition: One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants.
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid.
We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $3,448
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $3,448
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 685.300 (b)(5) states “On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary;”
Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement.
Questioned Costs: N/A
Cause and Effect: The College experienced turnover in which it is believed that reconciliations of Direct Loan funds were not completed. Further, the College’s Financial Aid system had overwritten all reconciliations that had been completed for the year ended June 30, 2024. Therefore no documentation was able to be provided to support that reconciliations of Direct Loan funds were completed.
Recommendation: We recommend the College implement procedures in order to complete and retain monthly reconciliations for Direct Loan funds.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response
is included in the Corrective Action Plan.
2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.163, 668.166 notes, “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 received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award 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.(34 CFR 668.163, 668.166)”.
Condition: During our testing of thirty-seven draw downs, we noted four individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $25,712
Cause and Effect: The condition was caused by changes in students enrollment statuses that were not caught in their reconciliation process which resulted in them requesting funds from the Common Origination and Disbursement (COD) system although they were no longer eligible for disbursements in the Spring semester due to graduating, withdrawing, or other circumstances. As a result, the College is retaining federal monies longer than allowed.
Recommendation: We recommend that the College implement procedures and cash controls to avoid having excess cash.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.163, 668.166 notes, “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 received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award 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.(34 CFR 668.163, 668.166)”.
Condition: During our testing of thirty-seven draw downs, we noted four individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $25,712
Cause and Effect: The condition was caused by changes in students enrollment statuses that were not caught in their reconciliation process which resulted in them requesting funds from the Common Origination and Disbursement (COD) system although they were no longer eligible for disbursements in the Spring semester due to graduating, withdrawing, or other circumstances. As a result, the College is retaining federal monies longer than allowed.
Recommendation: We recommend that the College implement procedures and cash controls to avoid having excess cash.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance requirement and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Effect: The College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.”
Condition: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003.
Statistical sampling was not used in making sample selections.
Questioned Costs: $809
Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-004 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.
Condition: One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants.
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid.
We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections.
Questioned Costs: $0
Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid.
Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary.
Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement.
Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements.
Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $3,448
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $3,448
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024.
Criteria: 34 CFR 685.300 (b)(5) states “On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary;”
Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement.
Questioned Costs: N/A
Cause and Effect: The College experienced turnover in which it is believed that reconciliations of Direct Loan funds were not completed. Further, the College’s Financial Aid system had overwritten all reconciliations that had been completed for the year ended June 30, 2024. Therefore no documentation was able to be provided to support that reconciliations of Direct Loan funds were completed.
Recommendation: We recommend the College implement procedures in order to complete and retain monthly reconciliations for Direct Loan funds.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response
is included in the Corrective Action Plan.