U.S. Department of Education Education Stabilization Fund 84.425 Federal award identification number P425E204935 Requirements: (A) Activities Allowed or Unallowed and (B) Allowable Costs Condition: For 37 tested grant disbursements to students, the College provided documentation of management approval, but was unable to provide documentation of Executive Committee approval. Criteria: Per 2 CFR section 200.303, recipients of federal awards must establish, document, and maintain effective internal controls to provide reasonable assurance that the recipient manages the federal award in compliance with statutes, regulations, terms and conditions applicable to the federal award. The College’s internal control policies state that all institutional expenses above $100 must be approved by an Executive Committee Member. Cause: The College failed to document this required approval due to management level staff turnover and new staff not being aware of the approval process. Effect: The College could not demonstrate that grant disbursements totaling $60,311 were approved by the Executive Committee. Repeat Finding: Repeat of 2022-07 Recommendation: RBT recommends that the College develop and document detailed controls over grants. Perspective: This control deficiency appears to be systemic and could impact an additional 497 grant disbursements totaling $800,540 that were not tested. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.038 84.038 does not have a FAIN # on the USASpending.gov website Requirements: (N7) Perkins Condition: The College could not provide support for one (1) outstanding Perkins loan balance of $174. This loan was paid off in 1989; however, the loan servicer did not apply the payment correctly. Criteria: Per 34 CFR 674.48, an institution that contracts any of its duties remains responsible for the duties performed by the contractor. Cause: The College did not review or reconcile the information received from the loan servicer. Effect: The College’s records were incorrect. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College continue to liquidate Perkins loans and verify all information received from the loan servicer. Perspective: This issue was not found on the other twenty-six (26) loans tested and does not appear to be systemic. Management’s Response: See corrective action plan.
U.S. Department of Education Education Stabilization Fund 84.425 Federal award identification number P425E204935 Requirements: (L) Reporting Condition: The College did not publicly post any of the four required quarterly student aid reports. Criteria: Per CRRSAA 314, recipients of CARES Act HEERF funding are required to provide public reporting of student aid funds disbursed. Cause: The College failed to comply due to a lack of policies and procedures in this area and a lack of knowledge of federal requirements among new management level staff. Effect: The College is not in compliance with federal regulations under the requirement of 31 USC Chapter 75 and 2 CFR Part 200, Subpart F. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College develop and follow detailed controls over federal grant requirements. Perspective: This issue appears to be systemic since it impacted all four quarterly reporting periods. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.038 84.038 does not have a FAIN # on the USASpending.gov website Requirements: (N7) Perkins Condition: The College does not keep the original paper promissory notes in a locked fireproof container. The notes are stored in boxes in storage areas. Criteria: Per 34 CFR 674.19, institutions are required to keep original paper promissory notes and repayment schedules in a locked fireproof container. Cause: Management was not aware of the document retention requirements and did not establish proper physical security controls over the original promissory notes. Effect: The documents could be lost or damaged. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College develop and follow detailed controls over securing these documents. Perspective: This issue appears to be systemic since it impacted all promissory notes. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.038 84.038 does not have a FAIN # on the USASpending.gov website Requirements: (N7) Perkins Condition: The College could not locate two (2) promissory notes out of twenty-seven (27) people tested. Criteria: Per 34 CFR 674.19, institutions must retain promissory and master promissory notes, and repayment records for each Perkins Loan program loan made. Cause: Management was not aware of the document retention requirements and did not establish proper physical security controls over the original promissory notes. Effect: The College is unable to prove the validity of amounts borrowed under these loans. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College develop and follow detailed controls over grant federal requirements. Perspective: This issue does not appear to be systemic as original promissory notes were provided for the other selections. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.007, 84.033, 84.063, 84.268, 84.038 84.038 does not have a FAIN # on the USASpending.gov website P007A222975, P033A222975, P063P221903, P268K231903 Requirements: (N9) Satisfactory Academic Progress Condition: The College’s written standards for measuring whether eligible students are maintaining satisfactory academic progress in their educational program did not contain all of the elements described in federal regulations. Criteria: Per 34 CFR 668.16(e), the College must establish and publish reasonable standards for measuring whether eligible students are maintaining satisfactory academic progress in their educational program. This policy should meet the requirements in 34 CFR 668.34. Cause: The College standards did not state when academic progress will be evaluated, state procedures for disbursements to students in a warning status, or provide for notification to students of the results of an evaluation that impacts eligibility, because management does not have a procedure to compare its policies to the criteria contained in the regulations. Effect: The College’s Satisfactory Academic Progress policy does not meet all of the criteria to be considered reasonable. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College update its Satisfactory Academic Progress policy to include all required criteria. We also recommend implementing a procedure to periodically review the policy to ensure it continues to meet the minimum requirements. Perspective: This issue impacts all student financial aid cluster programs. Management’s Response: See corrective action plan.
U.S. Department of Education Education Stabilization Fund 84.425 Federal award identification number P425E204935 Requirements: (A) Activities Allowed or Unallowed and (B) Allowable Costs Condition: For 37 tested grant disbursements to students, the College provided documentation of management approval, but was unable to provide documentation of Executive Committee approval. Criteria: Per 2 CFR section 200.303, recipients of federal awards must establish, document, and maintain effective internal controls to provide reasonable assurance that the recipient manages the federal award in compliance with statutes, regulations, terms and conditions applicable to the federal award. The College’s internal control policies state that all institutional expenses above $100 must be approved by an Executive Committee Member. Cause: The College failed to document this required approval due to management level staff turnover and new staff not being aware of the approval process. Effect: The College could not demonstrate that grant disbursements totaling $60,311 were approved by the Executive Committee. Repeat Finding: Repeat of 2022-07 Recommendation: RBT recommends that the College develop and document detailed controls over grants. Perspective: This control deficiency appears to be systemic and could impact an additional 497 grant disbursements totaling $800,540 that were not tested. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.038 84.038 does not have a FAIN # on the USASpending.gov website Requirements: (N7) Perkins Condition: The College could not provide support for one (1) outstanding Perkins loan balance of $174. This loan was paid off in 1989; however, the loan servicer did not apply the payment correctly. Criteria: Per 34 CFR 674.48, an institution that contracts any of its duties remains responsible for the duties performed by the contractor. Cause: The College did not review or reconcile the information received from the loan servicer. Effect: The College’s records were incorrect. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College continue to liquidate Perkins loans and verify all information received from the loan servicer. Perspective: This issue was not found on the other twenty-six (26) loans tested and does not appear to be systemic. Management’s Response: See corrective action plan.
U.S. Department of Education Education Stabilization Fund 84.425 Federal award identification number P425E204935 Requirements: (L) Reporting Condition: The College did not publicly post any of the four required quarterly student aid reports. Criteria: Per CRRSAA 314, recipients of CARES Act HEERF funding are required to provide public reporting of student aid funds disbursed. Cause: The College failed to comply due to a lack of policies and procedures in this area and a lack of knowledge of federal requirements among new management level staff. Effect: The College is not in compliance with federal regulations under the requirement of 31 USC Chapter 75 and 2 CFR Part 200, Subpart F. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College develop and follow detailed controls over federal grant requirements. Perspective: This issue appears to be systemic since it impacted all four quarterly reporting periods. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.038 84.038 does not have a FAIN # on the USASpending.gov website Requirements: (N7) Perkins Condition: The College does not keep the original paper promissory notes in a locked fireproof container. The notes are stored in boxes in storage areas. Criteria: Per 34 CFR 674.19, institutions are required to keep original paper promissory notes and repayment schedules in a locked fireproof container. Cause: Management was not aware of the document retention requirements and did not establish proper physical security controls over the original promissory notes. Effect: The documents could be lost or damaged. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College develop and follow detailed controls over securing these documents. Perspective: This issue appears to be systemic since it impacted all promissory notes. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.038 84.038 does not have a FAIN # on the USASpending.gov website Requirements: (N7) Perkins Condition: The College could not locate two (2) promissory notes out of twenty-seven (27) people tested. Criteria: Per 34 CFR 674.19, institutions must retain promissory and master promissory notes, and repayment records for each Perkins Loan program loan made. Cause: Management was not aware of the document retention requirements and did not establish proper physical security controls over the original promissory notes. Effect: The College is unable to prove the validity of amounts borrowed under these loans. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College develop and follow detailed controls over grant federal requirements. Perspective: This issue does not appear to be systemic as original promissory notes were provided for the other selections. Management’s Response: See corrective action plan.
U.S. Department of Education Student Financial Aid Cluster 84.007, 84.033, 84.063, 84.268, 84.038 84.038 does not have a FAIN # on the USASpending.gov website P007A222975, P033A222975, P063P221903, P268K231903 Requirements: (N9) Satisfactory Academic Progress Condition: The College’s written standards for measuring whether eligible students are maintaining satisfactory academic progress in their educational program did not contain all of the elements described in federal regulations. Criteria: Per 34 CFR 668.16(e), the College must establish and publish reasonable standards for measuring whether eligible students are maintaining satisfactory academic progress in their educational program. This policy should meet the requirements in 34 CFR 668.34. Cause: The College standards did not state when academic progress will be evaluated, state procedures for disbursements to students in a warning status, or provide for notification to students of the results of an evaluation that impacts eligibility, because management does not have a procedure to compare its policies to the criteria contained in the regulations. Effect: The College’s Satisfactory Academic Progress policy does not meet all of the criteria to be considered reasonable. Repeat Finding: Not a repeat finding Recommendation: RBT suggests that the College update its Satisfactory Academic Progress policy to include all required criteria. We also recommend implementing a procedure to periodically review the policy to ensure it continues to meet the minimum requirements. Perspective: This issue impacts all student financial aid cluster programs. Management’s Response: See corrective action plan.