Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.”
Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $1,500
Cause and Effect: 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 Subsidized Direct Loans.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 685.201 (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: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%).
We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. 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.
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.
Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA).
Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $280
Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance.
Recommendation: We recommend the College refund $280 and increase controls over student aid packaging.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.”
34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…"
Condition: The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans.
Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.”
Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections.
Questioned Costs: $4,126
Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education.
Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.”
Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.”
Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is 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: $306
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Criteria: 34 CFR 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.”
Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding.
Questioned Costs: $328
Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained.
Recommendation: We recommend the College return $328 to the Department.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.