Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid
Programs (material weakness):
Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30,
2024; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2024; Federal
Work-Study Program, FAL No. 84.033, June 30, 2024; Federal Direct Student Loan Program,
FAL No. 84.268, June 30, 2024
Criteria – Federal regulations governing Title IV programs.
Condition – Instances of noncompliance were noted as more fully described in the context
below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the various U.S.
Department of Education, Title IV, Student Financial Assistance Programs:
1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic
year. The College did not provide supporting documentation for successful appeals and
allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this
finding is $180,794.
2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or
incomplete timesheets. 34 CFR Part 675.
3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have
their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34
CFR 668.22.
4) Entrance and exit counseling documentation was not provided for first time borrowers,
withdrawn students or graduated students. 34 CFR 685.304.5) Cost of Attendance Budgets to determine students unmet need were not provided by the
College. 34 CFR 685.102(b).
6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations
Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and
Federal Work-Study.
7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the
Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and
Federal Direct Loans. CFR 685.300(b)(5).
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – The College should implement corrective actions to ensure that
the above findings are resolved and do not recur in future periods. Moreover, internal controls
over compliance with federal program regulations should be revisited to ensure adequate
supervisory controls, quality assurance reviews of processes, and policies and procedures are
being updated and adhered to for compliance purposes.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.
Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30,
2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound
Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers,
FAL No. 84.066A, June 30, 2024
Criteria – Federal regulations governing TRIO programs.
Condition – Instances of noncompliance were noted as more fully described in the context below.
Questioned Costs – See below
Context – We observed the following conditions in connection with our testing of the TRIO
programs:
(a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the application,
ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not provided
for 17 students, one (1) student did not have any information uploaded, and one (1) student
has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Cause – Oversight by responsible employees of properly monitoring regulatory requirements.
Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions
as applicable.
Repeat Finding – None
Auditor's Recommendation – We recommend the College ensure that all required
documentation is submitted prior to determining the participants' eligibility.