Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must accurately report the enrollment status of all students regardless of whether they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reporting for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Additionally, the College did not have a control process in place to ensure timely and accurate reporting. Questioned Costs: None. Context: In our statistically valid sample of 60 students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 22 students that had the campus enrollment status reported incorrectly, 24 students had incorrect enrollment effective date, 60 students were reported past the 60-day reporting timeframe, 60 students were not certified every 60 days, five students had no record listed in NSLDS, three students where NSLDS Program enrollment effective date did not match the institutions records, two students where the students NSLDS Program enrollment status did not match the institutions records, one student had incorrect program length, and one student had a program begin date that did not match institutional records. Additionally, there was no review process to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institution’s records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes. 2023-004. Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriate federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In cases where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Unclaimed Title IV FSA funds must not escheat to the state, revert to the College, or be transferred to any other third party. Any Title IV, HEA credit balance must be paid directly to the student or parent promptly, within 14 days of its occurrence, whether before or after the first day of class for a given payment period. Condition: The College does not have a control in place to specifically monitor outstanding Title IV federal funded checks issued to students. This absence of oversight prevents the College from ensuring that these funds are returned within 240 days of check issuance. Additionally, the College does not have a control in place to monitor that student refunds are disbursed within 14 days of its occurrence. Questioned Costs: None. Context: During our testing, it was noted the College did not have a control in place to ensure the return of outstanding Title IV federally funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. It was also noted that the College did not have a control in place to ensure student refunds are disbursed to students within 14 days of its occurrence. Cause: The College does not have a control in place to ensure federal refunds are sent to students within 14 days and that any uncashed federal checks over 240 days are sent back to the Department of Education. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over outstanding checks and refunds of disbursements to students. Repeat Finding: No. Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks and the refunds of disbursements to students throughout the year. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements over direct loan reconciliations as well as the reconciliation of Pell, Federal Supplemental Educational Opportunity Grant (FSEOG), and Federal Work Study (FWS) Condition: The College did not have an internal control in place to ensure the direct loan monthly reconciliations were completed timely and accurately. In addition, the College also did not have a control in place to ensure the Pell, FSEOG, and FWS funds were reconciled timely and accurately. Questioned Costs: None. Context: During our testing, we noted the College did not have a formal review process in place to ensure the direct loan reconciliations were completed timely and accurately in accordance with federal regulations. The College also did not have formal review processes for reconciliations over other Title IV funding like Pell, FSEOG and FWS. Cause: The College did not have an internal control in place to review and approve direct loan, Pell, FSEOG, and FWS reconciliations. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over the direct loan, Pell, FSEOG, and FWS reconciliations. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure direct loan, Pell, FSEOG, and FWS reconciliations are reviewed and such review properly documented. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: 34 CFR 668.22(a)(1) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment that the recipient began attendance in, the institution must determine the amount of Title IV assistance that the student earned in accordance with 34 CFR 668.22(e) which states that the calculation to determine this is equal to the percentage of the period of enrollment that the student completed as of the withdrawal date if this date occurs before completion of 60% of the period of enrollment. The amount unearned by the student is the complement of this percentage and is required to be returned as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as described in 34 CFR 668.22(j)(1). The withdrawal date is the date by which the student began the withdrawal process or provided official notification to the institution of intent to withdraw. If the student ceased attendance without providing notification to the institution the midpoint of the period of enrollment should be used. If the student’s ceasing attendance is due to illness, accident, or other circumstance beyond the students control the withdrawal date is date the institution becomes aware of these circumstances, as described in 668.22(c). Further (j)(2) states an institution not required to take attendance must determine the withdraw date for students who withdraw without providing notification to the institution no later than 30. Criteria or specific requirement (continued): days after the end of the earlier of the period of enrollment, academic year in which withdrawal occurred, or education program for which the student withdrew. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain effective internal controls designed to reasonably ensure compliance with federal laws, regulations, and program requirements related to these awards. Condition: The College did not accurately determine student withdrawal dates, leading to incorrect Return of Title IV (R2T4) calculations. Additionally, withdrawals were not identified in a timely manner, and funds were not returned within the required 45-day period. The College also lacked internal controls to ensure the R2T4 process complied with federal regulations and guidelines. Questioned Costs: None. Context: During our testing, we identified exceptions in 7 out of 16 sampled student records. Specifically: • 5 students had incorrect withdrawal dates recorded. • 2 students had Return of Title IV (R2T4) calculations that were not accurately performed. • 3 students experienced delays in withdrawal determination beyond 30 days of their enrollment period, and for these same students, funds were not returned to COD within the required 45-day timeframe. Furthermore, the College lacks a formal review process to ensure adherence to federal laws, regulations, and program compliance requirements. Cause: The College did not establish precise controls to ensure compliance with federal laws, regulation and program compliance requirements over R2T4. Effect: The lack of an internal control to ensure compliance with federal requirements could result in errors going undetected by the College. Repeat Finding: Yes, 2023-005, 2023-008. Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College implement a formal review process to ensure the R2T4 calculations being prepared timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards must establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, regulations, and the terms and conditions of the award. Condition: The College did not properly identify students on Satisfactory Academic Progress (SAP) suspension, resulting in disbursement of aid to ineligible students. Questioned Costs: $21,381 Context: During our testing of 60 students, we noted 8 students who did not meet SAP requirements and were not placed on SAP suspension. Cause: The students' SAP statuses were not being calculated within the College’s system due to a known system issue and notifications of a change in SAP standing were not sent out to students. Effect: Ineligible students received Title IV funds. Repeat Finding: 2023-008. Recommendation: We recommend the College strengthen its internal controls to ensure timely identification of students not meeting SAP standards. Additionally, the College should work with its system administrator to resolve the SAP calculation issue or implement an alternative method for tracking SAP compliance. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states “In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all such students who will receive Pell Grants, the institution may award the remaining funds to other eligible students.” Furthermore, institutions are required to ensure that only eligible recipients receive Federal Pell Grants. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, statutes, regulations and terms and conditions of the federal award. Condition: The College awarded FSEOG funds to students with Expected Family Contributions (EFCs) above zero, while eligible students with zero EFCs were not awarded. Questioned Costs: None. Context: Out of 8 FSEOG recipients tested, one FSEOG recipient had an EFC greater than zero while eligible students with zero EFCs were not awarded FSEOG. Cause: A reporting error in the financial aid system misclassified a student’s EFC, leading to incorrect award decisions. Effect: The College did not comply with FSEOG awarding guidelines, which prioritize students with the lowest EFCs. Repeat Finding: No. Recommendation: We recommend the College review its FSEOG awarding procedures and strengthen controls to ensure accurate identification and prioritization of eligible students based on EFC. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: In accordance with 2 CFR 200.358 the recipient must submit financial reports as required by the Federal award. The grant requirements state that the recipient must submit form SF-425 on a semi-annual basis for the periods ending March 31 and September 30, or any portion thereof. 2 CFR 200.328(c) requires these semi-annual reports be submitted no later than 30 days after the reporting period. Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not submit the required SF-425 report for the period ending March 31, 2024. Questioned Costs: None. Context: During our testing of financial reports, the College was unable to provide the SF-425 report for the period ending March 31, 2024. Cause: The College was not aware that this report had not been submitted. Effect: The College was not in compliance with the Department of Commerce regulations for timely and accurate reporting of the SF-425 report. Repeat Finding: No. Recommendation: We recommend the College review its reporting procedures to ensure all reports are completed and submitted timely. Views of responsible officials: There is no disagreement with the finding.
Criteria or specific requirement: In accordance with 29 CFR section 5.5, Davis-Bacon Act (currently known as Wage Rate Requirements) requires that all contractors and subcontractors performing on federal contracts (and contractors or subcontractors performing on federally assisted contracts under the related Acts) in excess of $2,000 pay their laborers and mechanics not less than the prevailing wage rates and fringe benefits listed in the contract’s Davis-Bacon wage determination for corresponding classes of laborers and mechanics employed on similar projects in the area. Each covered contractor and subcontractor must, on a weekly basis, provide the entity with a copy of all payrolls providing the information listed under 29 CFR 5.5(a)(3)(ii)(B) for the preceding weekly payroll period. The contractor, subcontractor or authorized officer or employee of the contractor or subcontractor who supervises the payment of wages must sign the weekly payroll and certification statement. Further Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not receive or review the required weekly certified payrolls from subcontractors and contractors. Questioned Costs: None. Context: During our testing of two contracts with contractors/subcontractors that were subject to the Davis-Bacon wage rate requirements the College did not obtain the certified payrolls from the contactors/subcontractors and document their review and approval of them. Cause: The College was not aware of the requirement to obtain and review weekly certified payrolls prior to processing the vendor payment. Effect: The College was not in compliance with the Department of Commerce’s wage rate requirements under special tests and provisions. Repeat Finding: No. Recommendation: We recommend the College strengthen its process for obtaining certified payrolls and implement procedures to ensure timely receipt, review, and documentation of these reports. Views of responsible officials: There is no disagreement with the finding.