Audit 376153

Finding 2025-001 Student Financial Aid Cluster Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268) Criteria: Uniform Guidance (2 CFR 200.303) requires institutions administering federal programs to establish and maintain effective internal controls to provide reasonable assurance of compliance with federal statutes, regulations, and terms and conditions of awards. Additionally, Title IV regulations further require institutions to accurately calculate and disburse financial aid based on student eligibility These controls should include maintaining documentation on file of the calculations performed to determine eligibility and award amounts. Condition: Our financial aid sample of 40 items tested yielded 33 students who received Pell Grant Funding, 27 students who received Subsidized Direct Loans and 24 students who received Unsubsidized Direct Loans. Of the students tested, we noted five instances where students did not receive the correct amount of aid, per our independent calculations and those performed by WCCC. Please refer to page 80 of the June 30, 2025 audit report for details. Additionally, Of the 40 students selected for testing, the cost of attendance within the student financial aid module maintained within WCCC’s enterprise-wide software, did not agree with calculations done by the auditors and/or financial aid staff and could not be relied upon to reperform calculations to determine proper award amounts. Cause: As a result of calculation errors brought about by the issues with the student financial aid module, aid was not calculated and disbursed correctly. Documented controls were not in place to ensure students received the proper amount of Student Financial Assistance they were entitled to receive. Effect: WCCC is not in compliance with required calculations for student financial assistance funding. WCCC may be liable to return funds to the Department of Education related to overpayments to students or students may not have received the total amount of funding that they were eligible for. Repeat Finding: This is a repeat finding of 2024-002, 2023-003. Questioned costs: Known: $7,045, Likely : $378,420 Based on our testing of student financial aid disbursements, we identified five instances in which students did not receive the correct amount of aid. The differences associated with these items total $7,045 and are reported as known questioned costs. In addition, by projecting known questioned costs identified in the eligibility audit sample to the entire population from which the sample was drawn results in likely questioned costs of $378,420. Recommendation: We recommend that WCCC review policies and procedures to ensure that proper procedures are in place verifying the accuracy of student eligibility for grant funding and that the proper amount is paid to the student based on financial need. Additionally, the calculations prepared to determine award amounts should be maintained on file. Ideally, the enterprise-wide student financial aid module should contain the appropriate information and demonstrate the appropriate calculations. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.

Finding 2025-002 Student Financial Aid Cluster Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (ALN #’s - 84.063, 84.033, 84.007, 84.268) Criteria: Institutions are required to submit Direct Loan and Pell Grant origination records and disbursement records to the Common Origination and Disbursement System (COD). Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for payment. An institution follows up with a disbursement record for that student. The disbursement record reports the actual disbursement date and the amount of the disbursement. Additionally, the enrollment date, verification status code, if applicable, and cost of attendance should be accurately reported to COD. Condition: Our review of the COD reports for 40 students, yielded 24 instances in which the Cost of Attendance did not match the records of WCCC. We noted an additional 5 instances in which the amount reported to COD matched the records within Anthology, however, as noted in finding 2025-001, the amounts within Anthology were noted to be miscalculated. Cause: Controls were not in place to ensure that accurate information was being submitted to COD. Effect: Failure to accurately report cost of attendance, disbursement amounts and disbursement dates to the COD can cause errors in reporting student aid eligibility, violations of federal cash management requirements and creates reconciliation discrepancies between the Department of Ed’s system and the institution’s records. Repeat Finding: This is a not a repeat finding. Questioned costs: Unknown Recommendation: We recommend that WCCC strengthen its internal controls over Title IC reporting to the Common Origination and Disbursement System by establishing a formal process to verify the accuracy of cost of attendance, disbursement amounts and disbursement dates prior to submission to COD and by developing monitoring reports and maintaining documentation of reviews and corrections to demonstrate compliance with the federal regulations. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan.