Audit 373530

Federal Program: Student Financial Aid Cluster – Significant Deficiency Federal Agency: Department of Education ALN Number: 84.063, 84.268, 84.033, 84.007 Criteria: The College is required to submit the Fiscal Operations Report and Application to Participate (FISAP) annually to receive funds for the campus-based programs. Condition: The College incorrectly reported information on tuition and fees in the FISAP submitted to the Department of Education. Additionally, the College did not maintain records of supporting the Distribution of Program Recipients and Expenditures by Type of Student in Part VI, Program Summary for Award Year. Questioned Costs: None Cause: Employee turnover. Effect: The College did not operate in accordance with the special reporting compliance requirement. Recommendation: The College should develop procedures to have the financial aid and financial accounting information systems reconciled on a monthly basis. These reconciliation will ensure accurate reporting during periods of turnover of key personnel. Grantee Comment: Refer to Corrective Action Plan

Federal Program: Student Financial Aid Cluster – Significant Deficiency Federal Agency: Department of Education ALN Number: 84.063, 84.268, 84.033, 84.007 Criteria: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as that student’s campus-level enrollment status for all programs the student is enrolled in at that location, even if the student is not currently taking coursework that applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for that program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. 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. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report eleven students’ Campus-Level enrollment status change to NSLDS. Context: Out of the 27 students tested, we noted 11 students whose status change at the Program- Level and Campus-Level was not timely reported to NSLDS. Questioned costs There were no questioned costs with respect to this finding. Cause: The College did not have formally documented controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance. Effect: Student status changes exceeded the 60-day period for student enrollment changes reported in roster files. Recommendation: We recommend the College review current processes and implement updated processes and controls for reporting to NSLDS, implementing procedures to ensure submissions are reported timely and accurately. In addition, we recommend the College review the reporting in the system to ensure it can pull accurate reports of student enrollment status. Grantee Comments: See corrective action plan.

Federal Agency: Department of Education ALN Number: 84.063, 84.268, 84.033, 84.007 Criteria: Per the requirements under the program under CFR 667.22(j)(1), institutions must return unearned Title IV funds within 45 days of the date the institution determined the student withdrew. Condition: During our testing, we noted that the College did not properly (or timely) calculate (or return timely) Title IV funds. While some of our testing selections resulted in the ability to calculate amounts that needed to be returned, many of our testing selections were unable to be completely tested in order to derive exact amounts that should be returned. Context: Out of a sample of 25 students selected for testing, we identified 2 students that would have had a return requirement that went unidentified until the audit was conducted. Further, during our testing, the College had trouble providing supporting documentation to support the exact withdrawal date, therefore, we were unable to accurately determine the exact amounts that should be returned for some of our selections. Out of our 25 student selections, 12 of our selections were unable to be fully tested to determine whether a return requirement was present. Questioned Costs: Unknown. Cause: Lack of clear and timely documentation and communication between registrar and financial aid office. Effect: The College did not operate in accordance with the special reporting compliance requirement. Recommendation: The College should develop procedures to have the financial aid and registrar information systems be kept in sync with each other, and clear and definitive documentation relating to student changes in enrollment should be kept consistently between offices. This will ensure proper consideration of the special reporting compliance requirement is properly given. Grantee Comment: Refer to Corrective Action Plan