Audit 35306

FY End
2022-06-30
Total Expended
$7.43M
Findings
8
Programs
5
Organization: Moore College of Art & Design (PA)
Year: 2022 Accepted: 2023-02-13

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
33471 2022-002 Significant Deficiency - L
33472 2022-003 Significant Deficiency Yes N
33473 2022-001 Significant Deficiency - N
33474 2022-003 Significant Deficiency Yes N
609913 2022-002 Significant Deficiency - L
609914 2022-003 Significant Deficiency Yes N
609915 2022-001 Significant Deficiency - N
609916 2022-003 Significant Deficiency Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $5.80M Yes 2
84.063 Federal Pell Grant Program $742,455 Yes 1
84.038 Federal Perkins Loan Program $686,547 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $111,033 Yes 0
84.033 Federal Work-Study Program $89,948 Yes 1

Contacts

Name Title Type
LG9NPAPCPJ25 William L. Hill, II Auditee
2159654022 Joseph C. Sassa, III Auditor
No contacts on file

Notes to SEFA

Title: Federal Perkins Loan Program Accounting Policies: Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Federal Perkins Loan Program is administered directly by the College, and balances and transactions relating to this program are included in the College's basic financial statements. Loans outstanding at the beginning of the year and loans made during the year are included in the federal expenditures presented in the Schedule. The balance of loans outstanding at June 30, 2022 was $637,210.

Finding Details

Finding 2022-002 - Reporting Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.033 Federal Award Number: P033A203647 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 674.19(d)(2), 34 CFR 675.19(b)(3) and 34 CFR 676.19(b)(3)) require institutions to submit a Fiscal Operations Report and Application to Participate (FISAP) annually and to ensure that the information reported on the FISAP is accurate. Condition/Context: During our testing of the June 30, 2021 FISAP, one error was noted. The sample was not a statistically valid sample. Questioned Costs: None noted. Cause: Included in the total Federal Work Study (FWS) was $19,845 from the Pennsylvania Higher Education Assistance Agency (PHEAA) FWS On Program which should not have been included in this total amount since it was not federal funds. Effect: Certain balances related to the College's federal programs are not being accurately represented to the Department of Education. Recommendation: The College should review and revise its procedures for the FISAP preparation and review to ensure accurate information is reported on the FISAP in a timely manner. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, it is clear that additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.
Finding 2022-003 - Return of Title IV Funds Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.063, 84.268 Federal Award Number: PK268K222121, P063P212121 Federal Award Year: June 30, 2022 Repeat Finding: 2021-001 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for two of five students tested as part of our sample were not calculated correctly and resulted in the College refunding incorrect amounts to the Title IV Program. In addition, the College identified five other students for which the R2T4 calculations were incorrect. The sample was not a statistically valid sample. Questioned Costs: For federal award P268K222121, Direct Loans, the College returned $14 more than required for one student tested. For federal award P063P212121, Pell, the college returned $67 more than required for one student. For the five additional students that the College identified as having incorrect return calculations, $457 was returned in excess for award P063P212121 and $84 was returned in excess for award P268K222121. Cause: The College did not properly calculate the number of days in a term (excluding breaks of five days or more) which resulted in the incorrect unearned aid percentage to be used in the refund calculation. Effect: The amounts refunded to the Department of Education were incorrect. To be specific, the amount returned was more than should have been returned. Recommendation: The College should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations in order to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.
Finding 2022-001 - Verification Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.268 Federal Award Number: P268K222121 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional Federal Perkins Loan or FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition/Context: For one student tested out of total population of one student for V4/V5 verification who received subsidized and unsubsidized direct loans, there was no documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), was completed prior to Federal funds being disbursed to students. The sample was not a statistically valid sample. Questioned Costs: The total direct loans disbursed to the student during fiscal year 2022 was $10,392. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendation: We recommend that the School put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Actions: The U.S. Department of Education waived the requirement for verification for academic year 2021/2022 for V1, V2 and V3 students, however institutions were required to complete verification for V4 and V5 students. All of the College's students fell under V1, V2 and V3 except for one student. The College has created a selection set in its financial aid software to identify these students so they will be selected for verification. Finding 2022-001 - Verification Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.268 Federal Award Number: P268K222121 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional Federal Perkins Loan or FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition/Context: For one student tested out of total population of one student for V4/V5 verification who received subsidized and unsubsidized direct loans, there was no documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), was completed prior to Federal funds being disbursed to students. The sample was not a statistically valid sample. Questioned Costs: The total direct loans disbursed to the student during fiscal year 2022 was $10,392. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendation: We recommend that the School put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Actions: The U.S. Department of Education waived the requirement for verification for academic year 2021/2022 for V1, V2 and V3 students, however institutions were required to complete verification for V4 and V5 students. All of the College's students fell under V1, V2 and V3 except for one student. The College has created a selection set in its financial aid software to identify these students so they will be selected for verification.
Finding 2022-003 - Return of Title IV Funds Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.063, 84.268 Federal Award Number: PK268K222121, P063P212121 Federal Award Year: June 30, 2022 Repeat Finding: 2021-001 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for two of five students tested as part of our sample were not calculated correctly and resulted in the College refunding incorrect amounts to the Title IV Program. In addition, the College identified five other students for which the R2T4 calculations were incorrect. The sample was not a statistically valid sample. Questioned Costs: For federal award P268K222121, Direct Loans, the College returned $14 more than required for one student tested. For federal award P063P212121, Pell, the college returned $67 more than required for one student. For the five additional students that the College identified as having incorrect return calculations, $457 was returned in excess for award P063P212121 and $84 was returned in excess for award P268K222121. Cause: The College did not properly calculate the number of days in a term (excluding breaks of five days or more) which resulted in the incorrect unearned aid percentage to be used in the refund calculation. Effect: The amounts refunded to the Department of Education were incorrect. To be specific, the amount returned was more than should have been returned. Recommendation: The College should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations in order to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.
Finding 2022-002 - Reporting Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.033 Federal Award Number: P033A203647 Federal Award Year: June 30, 2022 Criteria: Title IV regulations (34 CFR 674.19(d)(2), 34 CFR 675.19(b)(3) and 34 CFR 676.19(b)(3)) require institutions to submit a Fiscal Operations Report and Application to Participate (FISAP) annually and to ensure that the information reported on the FISAP is accurate. Condition/Context: During our testing of the June 30, 2021 FISAP, one error was noted. The sample was not a statistically valid sample. Questioned Costs: None noted. Cause: Included in the total Federal Work Study (FWS) was $19,845 from the Pennsylvania Higher Education Assistance Agency (PHEAA) FWS On Program which should not have been included in this total amount since it was not federal funds. Effect: Certain balances related to the College's federal programs are not being accurately represented to the Department of Education. Recommendation: The College should review and revise its procedures for the FISAP preparation and review to ensure accurate information is reported on the FISAP in a timely manner. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, it is clear that additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.
Finding 2022-003 - Return of Title IV Funds Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.063, 84.268 Federal Award Number: PK268K222121, P063P212121 Federal Award Year: June 30, 2022 Repeat Finding: 2021-001 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for two of five students tested as part of our sample were not calculated correctly and resulted in the College refunding incorrect amounts to the Title IV Program. In addition, the College identified five other students for which the R2T4 calculations were incorrect. The sample was not a statistically valid sample. Questioned Costs: For federal award P268K222121, Direct Loans, the College returned $14 more than required for one student tested. For federal award P063P212121, Pell, the college returned $67 more than required for one student. For the five additional students that the College identified as having incorrect return calculations, $457 was returned in excess for award P063P212121 and $84 was returned in excess for award P268K222121. Cause: The College did not properly calculate the number of days in a term (excluding breaks of five days or more) which resulted in the incorrect unearned aid percentage to be used in the refund calculation. Effect: The amounts refunded to the Department of Education were incorrect. To be specific, the amount returned was more than should have been returned. Recommendation: The College should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations in order to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.
Finding 2022-001 - Verification Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.268 Federal Award Number: P268K222121 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional Federal Perkins Loan or FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition/Context: For one student tested out of total population of one student for V4/V5 verification who received subsidized and unsubsidized direct loans, there was no documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), was completed prior to Federal funds being disbursed to students. The sample was not a statistically valid sample. Questioned Costs: The total direct loans disbursed to the student during fiscal year 2022 was $10,392. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendation: We recommend that the School put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Actions: The U.S. Department of Education waived the requirement for verification for academic year 2021/2022 for V1, V2 and V3 students, however institutions were required to complete verification for V4 and V5 students. All of the College's students fell under V1, V2 and V3 except for one student. The College has created a selection set in its financial aid software to identify these students so they will be selected for verification. Finding 2022-001 - Verification Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.268 Federal Award Number: P268K222121 Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.60(b)(1) states that if an applicant fails to provide the requested verification documentation that the institution may not disburse any additional Federal Perkins Loan or FSEOG Program funds to the applicant, employ, continue to employ or allow an employer to employ the applicant under FWS, or originate the applicant's Direct Subsidized Loan or disburse any additional Direct Subsidized Loan proceeds for the applicant. Condition/Context: For one student tested out of total population of one student for V4/V5 verification who received subsidized and unsubsidized direct loans, there was no documentation that verification procedures, including the verification of the income reported on the Free Application for Federal Student Aid (FAFSA), was completed prior to Federal funds being disbursed to students. The sample was not a statistically valid sample. Questioned Costs: The total direct loans disbursed to the student during fiscal year 2022 was $10,392. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendation: We recommend that the School put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Actions: The U.S. Department of Education waived the requirement for verification for academic year 2021/2022 for V1, V2 and V3 students, however institutions were required to complete verification for V4 and V5 students. All of the College's students fell under V1, V2 and V3 except for one student. The College has created a selection set in its financial aid software to identify these students so they will be selected for verification.
Finding 2022-003 - Return of Title IV Funds Federal Program: Student Financial Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable CFDA Number: 84.063, 84.268 Federal Award Number: PK268K222121, P063P212121 Federal Award Year: June 30, 2022 Repeat Finding: 2021-001 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for two of five students tested as part of our sample were not calculated correctly and resulted in the College refunding incorrect amounts to the Title IV Program. In addition, the College identified five other students for which the R2T4 calculations were incorrect. The sample was not a statistically valid sample. Questioned Costs: For federal award P268K222121, Direct Loans, the College returned $14 more than required for one student tested. For federal award P063P212121, Pell, the college returned $67 more than required for one student. For the five additional students that the College identified as having incorrect return calculations, $457 was returned in excess for award P063P212121 and $84 was returned in excess for award P268K222121. Cause: The College did not properly calculate the number of days in a term (excluding breaks of five days or more) which resulted in the incorrect unearned aid percentage to be used in the refund calculation. Effect: The amounts refunded to the Department of Education were incorrect. To be specific, the amount returned was more than should have been returned. Recommendation: The College should reevaluate the process around completing R2T4 calculations. Also, a more rigorous review process should be implemented over refund calculations in order to ensure the proper calculations of the R2T4 worksheet. Views of Responsible Officials and Planned Corrective Actions: The College hired a new Director of Financial Aid in January 2021 and the academic year 2020/2021 was the first one she completed. While the College hired an external consultant to assist her, additional training in this area is necessary. The College has since hired a new Director of Financial Aid who has more years of experience in the field. The College will be providing additional consulting support going forward when a new Director of Financial Aid is hired.