Audit 359811

Finding: Item 2024-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was submitted to the NSLDS timely. Repeat finding: Not a repeat finding. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Finding: Item 2024-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Condition / context: Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed timely for two students that required a return of funds. Additionally, the Title IV worksheet was not completed accurately for one student. There was a delay in return of Title IV funds for all three of these students that exceeded the maximum time allowed of 45 days after the date the institution determined that the student withdrew. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the Title IV worksheet was completed accurately and returns were processed timely. Repeat finding: Finding is a repeat of finding 2023-002 in the immediately prior audit. Effect: Inaccurate calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed accurately and correctly to ensure that amounts earned by students who withdraw from the College are calculated correctly to ensure timely processing of returns, if any. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Finding: Item 2024-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Condition / context: Out of a sample of 27 students who received Federal Pell Grants during the audit period, nine students did not have the correct disbursement date submitted to the COD system. The discrepancies in dates submitted and actual dates disbursed ranged from one to five days. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Repeat finding: Not a repeat finding. Effect: Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. Recommendation: We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Finding: Item 2024-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was submitted to the NSLDS timely. Repeat finding: Not a repeat finding. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Finding: Item 2024-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Condition / context: Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed timely for two students that required a return of funds. Additionally, the Title IV worksheet was not completed accurately for one student. There was a delay in return of Title IV funds for all three of these students that exceeded the maximum time allowed of 45 days after the date the institution determined that the student withdrew. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the Title IV worksheet was completed accurately and returns were processed timely. Repeat finding: Finding is a repeat of finding 2023-002 in the immediately prior audit. Effect: Inaccurate calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed accurately and correctly to ensure that amounts earned by students who withdraw from the College are calculated correctly to ensure timely processing of returns, if any. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Finding: Item 2024-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Condition / context: Out of a sample of 27 students who received Federal Pell Grants during the audit period, nine students did not have the correct disbursement date submitted to the COD system. The discrepancies in dates submitted and actual dates disbursed ranged from one to five days. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Repeat finding: Not a repeat finding. Effect: Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. Recommendation: We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.