Audit 350596

Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Enrollment Reporting Type of Finding: Material Weakness and Material Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately reporting all Campus-Level Record data elements. At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award Conditions found During our testwork over student enrollment reporting, we noted that the College did not report all changes to students’ status within the required 60 days. For 4 out of 40 students selected for enrollment reporting compliance testing, the College did not transmit the students’ status changes within the next NSLDS transmission after the school became aware of the change. The status changes for these four students were reported between 79 and 138 days after the College became aware of the students’ withdrawal. Additionally, while the College has controls in place to ensure that enrollment changes are reported within the 60 days required, the control does not ensure that the school is capturing changes for all students. Cause For one student noted above, Management communicated to us that it was an oversight as this student was already enrolled in the College’s graduate program. For the other three, Management communicated to us that transmission reports that are submitted during the summer months do not account for students who withdraw from the College at the end of the spring semester. These changes were not reported to NSLDS until the following fall semester when the student does not return. For the reasons noted above, we determined the related control in place at the College, which is supposed to address the completeness of the transmission reports, does not operate at a precise enough level to ensure that the reports include all student status changes that have occurred since the prior transmission. Proper perspective The College’s policy is to run a report from the Colleague system and submit it to NSLDS for any student status changes. Out of an initial sample of 40 students who had status changes, we identified four students’ whose status changes were not reported within 60 days. Upon further review by Management, there was a total of 65 students who withdrew or took a leave of absence after the 2024 spring semester. Of these 65 students, the College did not communicate the status change for 32 of them within the required 60 days. The status change for these 32 students, including the four noted above, were reported between 79 and 248 days after the College became aware of the students’ withdrawal or leave of absence. Possible asserted effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College implement additional controls to ensure the completeness of the transmission reports before sending to NSLDS. Additionally, students who communicate to the University that they are withdrawing should have their status changed in the Colleague system and therefore be included on the next transmission report. View of responsible officials Between the conclusion of the spring term and the start of the fall term, the College reported summer enrollments. However, withdrawals from students who were not enrolled in summer terms were mistakenly held until the initial fall term reporting file.

Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Enrollment Reporting Type of Finding: Material Weakness and Material Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately reporting all Campus-Level Record data elements. At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award Conditions found During our testwork over student enrollment reporting, we noted that the College did not report all changes to students’ status within the required 60 days. For 4 out of 40 students selected for enrollment reporting compliance testing, the College did not transmit the students’ status changes within the next NSLDS transmission after the school became aware of the change. The status changes for these four students were reported between 79 and 138 days after the College became aware of the students’ withdrawal. Additionally, while the College has controls in place to ensure that enrollment changes are reported within the 60 days required, the control does not ensure that the school is capturing changes for all students. Cause For one student noted above, Management communicated to us that it was an oversight as this student was already enrolled in the College’s graduate program. For the other three, Management communicated to us that transmission reports that are submitted during the summer months do not account for students who withdraw from the College at the end of the spring semester. These changes were not reported to NSLDS until the following fall semester when the student does not return. For the reasons noted above, we determined the related control in place at the College, which is supposed to address the completeness of the transmission reports, does not operate at a precise enough level to ensure that the reports include all student status changes that have occurred since the prior transmission. Proper perspective The College’s policy is to run a report from the Colleague system and submit it to NSLDS for any student status changes. Out of an initial sample of 40 students who had status changes, we identified four students’ whose status changes were not reported within 60 days. Upon further review by Management, there was a total of 65 students who withdrew or took a leave of absence after the 2024 spring semester. Of these 65 students, the College did not communicate the status change for 32 of them within the required 60 days. The status change for these 32 students, including the four noted above, were reported between 79 and 248 days after the College became aware of the students’ withdrawal or leave of absence. Possible asserted effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College implement additional controls to ensure the completeness of the transmission reports before sending to NSLDS. Additionally, students who communicate to the University that they are withdrawing should have their status changed in the Colleague system and therefore be included on the next transmission report. View of responsible officials Between the conclusion of the spring term and the start of the fall term, the College reported summer enrollments. However, withdrawals from students who were not enrolled in summer terms were mistakenly held until the initial fall term reporting file.

Finding Number: 2024-002 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency Criteria An institution must credit a student’s account for the amount of Title IV funds the student is eligible to receive and pay the amount of any credit balances due before the institution seeks reimbursement from ED for those disbursements. The reimbursement request must include supporting documentation for the disbursements. After the reimbursement request is approved, ED initiates an electronic funds transfer to the institution’s account. Additionally, Schools participating in the Direct Loan program are required to perform monthly Direct Loan reconciliations (34 CFR 685.300(b)(5)). A school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. Each month, COD sends the school a School Account Statement, which is ED’s official record of the school’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the school. The school is required to account for any differences by reconciling ED’s records with the school’s financial and business records. Lastly, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Conditions found For a sample of three monthly bank reconciliations of the College’s main operating account, we noted there was no evidence of review by the Controller. Management communicated that the review of the bank reconciliation is part of the cash management process, but the Controller does not sign them. Each monthly bank reconciliation contains a ‘Prepared by’ and ‘Reviewed by’ sign-off line. For each sample, the Senior Staff Accountant signed off as the preparer, but the Controller did not sign off on the ‘Review by’ line. Cause Bank reconciliations are reviewed by the Controller, but there is no evidence that the control is properly being performed. Proper perspective The College’s policy is for the Controller to review bank reconciliations to ensure proper drawdowns are occurring. Out of a sample of three drawdowns, we noted the three bank reconciliations did not contain the Controller’s signature indicating proper review and approval. Possible asserted effect Not reviewing the bank reconciliation could cause the College to submit requests for reimbursement through the G5 system that are not complete or accurate. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College require that the Controller sign the bank reconciliation upon completing their review to signify that the reconciliation is complete and accurate. View of responsible officials The Controller was new to his position starting in December of 2023. He had reviewed all three of the bank reconciliations selected for audit review. However, he was not aware that the reconciliation actually required his signature per Emmanuel's policies and procedures to witness his review.

Finding Number: 2024-002 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency Criteria An institution must credit a student’s account for the amount of Title IV funds the student is eligible to receive and pay the amount of any credit balances due before the institution seeks reimbursement from ED for those disbursements. The reimbursement request must include supporting documentation for the disbursements. After the reimbursement request is approved, ED initiates an electronic funds transfer to the institution’s account. Additionally, Schools participating in the Direct Loan program are required to perform monthly Direct Loan reconciliations (34 CFR 685.300(b)(5)). A school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. Each month, COD sends the school a School Account Statement, which is ED’s official record of the school’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the school. The school is required to account for any differences by reconciling ED’s records with the school’s financial and business records. Lastly, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Conditions found For a sample of three monthly bank reconciliations of the College’s main operating account, we noted there was no evidence of review by the Controller. Management communicated that the review of the bank reconciliation is part of the cash management process, but the Controller does not sign them. Each monthly bank reconciliation contains a ‘Prepared by’ and ‘Reviewed by’ sign-off line. For each sample, the Senior Staff Accountant signed off as the preparer, but the Controller did not sign off on the ‘Review by’ line. Cause Bank reconciliations are reviewed by the Controller, but there is no evidence that the control is properly being performed. Proper perspective The College’s policy is for the Controller to review bank reconciliations to ensure proper drawdowns are occurring. Out of a sample of three drawdowns, we noted the three bank reconciliations did not contain the Controller’s signature indicating proper review and approval. Possible asserted effect Not reviewing the bank reconciliation could cause the College to submit requests for reimbursement through the G5 system that are not complete or accurate. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College require that the Controller sign the bank reconciliation upon completing their review to signify that the reconciliation is complete and accurate. View of responsible officials The Controller was new to his position starting in December of 2023. He had reviewed all three of the bank reconciliations selected for audit review. However, he was not aware that the reconciliation actually required his signature per Emmanuel's policies and procedures to witness his review.

Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Enrollment Reporting Type of Finding: Material Weakness and Material Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately reporting all Campus-Level Record data elements. At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award Conditions found During our testwork over student enrollment reporting, we noted that the College did not report all changes to students’ status within the required 60 days. For 4 out of 40 students selected for enrollment reporting compliance testing, the College did not transmit the students’ status changes within the next NSLDS transmission after the school became aware of the change. The status changes for these four students were reported between 79 and 138 days after the College became aware of the students’ withdrawal. Additionally, while the College has controls in place to ensure that enrollment changes are reported within the 60 days required, the control does not ensure that the school is capturing changes for all students. Cause For one student noted above, Management communicated to us that it was an oversight as this student was already enrolled in the College’s graduate program. For the other three, Management communicated to us that transmission reports that are submitted during the summer months do not account for students who withdraw from the College at the end of the spring semester. These changes were not reported to NSLDS until the following fall semester when the student does not return. For the reasons noted above, we determined the related control in place at the College, which is supposed to address the completeness of the transmission reports, does not operate at a precise enough level to ensure that the reports include all student status changes that have occurred since the prior transmission. Proper perspective The College’s policy is to run a report from the Colleague system and submit it to NSLDS for any student status changes. Out of an initial sample of 40 students who had status changes, we identified four students’ whose status changes were not reported within 60 days. Upon further review by Management, there was a total of 65 students who withdrew or took a leave of absence after the 2024 spring semester. Of these 65 students, the College did not communicate the status change for 32 of them within the required 60 days. The status change for these 32 students, including the four noted above, were reported between 79 and 248 days after the College became aware of the students’ withdrawal or leave of absence. Possible asserted effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College implement additional controls to ensure the completeness of the transmission reports before sending to NSLDS. Additionally, students who communicate to the University that they are withdrawing should have their status changed in the Colleague system and therefore be included on the next transmission report. View of responsible officials Between the conclusion of the spring term and the start of the fall term, the College reported summer enrollments. However, withdrawals from students who were not enrolled in summer terms were mistakenly held until the initial fall term reporting file.

Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Enrollment Reporting Type of Finding: Material Weakness and Material Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately reporting all Campus-Level Record data elements. At a minimum, institutions are required to certify enrollment every 60 days or every other month. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award Conditions found During our testwork over student enrollment reporting, we noted that the College did not report all changes to students’ status within the required 60 days. For 4 out of 40 students selected for enrollment reporting compliance testing, the College did not transmit the students’ status changes within the next NSLDS transmission after the school became aware of the change. The status changes for these four students were reported between 79 and 138 days after the College became aware of the students’ withdrawal. Additionally, while the College has controls in place to ensure that enrollment changes are reported within the 60 days required, the control does not ensure that the school is capturing changes for all students. Cause For one student noted above, Management communicated to us that it was an oversight as this student was already enrolled in the College’s graduate program. For the other three, Management communicated to us that transmission reports that are submitted during the summer months do not account for students who withdraw from the College at the end of the spring semester. These changes were not reported to NSLDS until the following fall semester when the student does not return. For the reasons noted above, we determined the related control in place at the College, which is supposed to address the completeness of the transmission reports, does not operate at a precise enough level to ensure that the reports include all student status changes that have occurred since the prior transmission. Proper perspective The College’s policy is to run a report from the Colleague system and submit it to NSLDS for any student status changes. Out of an initial sample of 40 students who had status changes, we identified four students’ whose status changes were not reported within 60 days. Upon further review by Management, there was a total of 65 students who withdrew or took a leave of absence after the 2024 spring semester. Of these 65 students, the College did not communicate the status change for 32 of them within the required 60 days. The status change for these 32 students, including the four noted above, were reported between 79 and 248 days after the College became aware of the students’ withdrawal or leave of absence. Possible asserted effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College implement additional controls to ensure the completeness of the transmission reports before sending to NSLDS. Additionally, students who communicate to the University that they are withdrawing should have their status changed in the Colleague system and therefore be included on the next transmission report. View of responsible officials Between the conclusion of the spring term and the start of the fall term, the College reported summer enrollments. However, withdrawals from students who were not enrolled in summer terms were mistakenly held until the initial fall term reporting file.

Finding Number: 2024-002 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency Criteria An institution must credit a student’s account for the amount of Title IV funds the student is eligible to receive and pay the amount of any credit balances due before the institution seeks reimbursement from ED for those disbursements. The reimbursement request must include supporting documentation for the disbursements. After the reimbursement request is approved, ED initiates an electronic funds transfer to the institution’s account. Additionally, Schools participating in the Direct Loan program are required to perform monthly Direct Loan reconciliations (34 CFR 685.300(b)(5)). A school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. Each month, COD sends the school a School Account Statement, which is ED’s official record of the school’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the school. The school is required to account for any differences by reconciling ED’s records with the school’s financial and business records. Lastly, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Conditions found For a sample of three monthly bank reconciliations of the College’s main operating account, we noted there was no evidence of review by the Controller. Management communicated that the review of the bank reconciliation is part of the cash management process, but the Controller does not sign them. Each monthly bank reconciliation contains a ‘Prepared by’ and ‘Reviewed by’ sign-off line. For each sample, the Senior Staff Accountant signed off as the preparer, but the Controller did not sign off on the ‘Review by’ line. Cause Bank reconciliations are reviewed by the Controller, but there is no evidence that the control is properly being performed. Proper perspective The College’s policy is for the Controller to review bank reconciliations to ensure proper drawdowns are occurring. Out of a sample of three drawdowns, we noted the three bank reconciliations did not contain the Controller’s signature indicating proper review and approval. Possible asserted effect Not reviewing the bank reconciliation could cause the College to submit requests for reimbursement through the G5 system that are not complete or accurate. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College require that the Controller sign the bank reconciliation upon completing their review to signify that the reconciliation is complete and accurate. View of responsible officials The Controller was new to his position starting in December of 2023. He had reviewed all three of the bank reconciliations selected for audit review. However, he was not aware that the reconciliation actually required his signature per Emmanuel's policies and procedures to witness his review.

Finding Number: 2024-002 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Pass-through Entity: N/A- Direct Award Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2023 through June 30, 2024 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency Criteria An institution must credit a student’s account for the amount of Title IV funds the student is eligible to receive and pay the amount of any credit balances due before the institution seeks reimbursement from ED for those disbursements. The reimbursement request must include supporting documentation for the disbursements. After the reimbursement request is approved, ED initiates an electronic funds transfer to the institution’s account. Additionally, Schools participating in the Direct Loan program are required to perform monthly Direct Loan reconciliations (34 CFR 685.300(b)(5)). A school must reconcile the funds it received from G5 with actual disbursement records the school submitted to COD. Each month, COD sends the school a School Account Statement, which is ED’s official record of the school’s cash and disbursement records and identifies the difference between the net draws from G5 and the actual disbursement information reported to COD by the school. The school is required to account for any differences by reconciling ED’s records with the school’s financial and business records. Lastly, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Conditions found For a sample of three monthly bank reconciliations of the College’s main operating account, we noted there was no evidence of review by the Controller. Management communicated that the review of the bank reconciliation is part of the cash management process, but the Controller does not sign them. Each monthly bank reconciliation contains a ‘Prepared by’ and ‘Reviewed by’ sign-off line. For each sample, the Senior Staff Accountant signed off as the preparer, but the Controller did not sign off on the ‘Review by’ line. Cause Bank reconciliations are reviewed by the Controller, but there is no evidence that the control is properly being performed. Proper perspective The College’s policy is for the Controller to review bank reconciliations to ensure proper drawdowns are occurring. Out of a sample of three drawdowns, we noted the three bank reconciliations did not contain the Controller’s signature indicating proper review and approval. Possible asserted effect Not reviewing the bank reconciliation could cause the College to submit requests for reimbursement through the G5 system that are not complete or accurate. Questioned costs None noted. Statistical sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat finding A similar finding was not reported in the prior year. Recommendation We recommend that the College require that the Controller sign the bank reconciliation upon completing their review to signify that the reconciliation is complete and accurate. View of responsible officials The Controller was new to his position starting in December of 2023. He had reviewed all three of the bank reconciliations selected for audit review. However, he was not aware that the reconciliation actually required his signature per Emmanuel's policies and procedures to witness his review.