Audit 376334

FY End
2025-06-30
Total Expended
$8.73M
Findings
2
Programs
3
Organization: Compass Rose Foundation, Inc. (FL)
Year: 2025 Accepted: 2025-12-19

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
1165668 2025-001 Material Weakness Yes N
1165669 2025-002 Material Weakness Yes N

Programs

ALN Program Spent Major Findings
84.268 FEDERAL DIRECT STUDENT LOANS $4.43M Yes 1
84.063 FEDERAL PELL GRANT PROGRAM $4.27M Yes 1
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $32,935 Yes 0

Contacts

Name Title Type
J3GUTRB2JHX6 Cindy Davis Auditee
9043285600 Michael Wherry Auditor
No contacts on file

Notes to SEFA

Basis of Presentation The accompanying schedule of expenditures of federal awards (Schedule) includes the federal award grant activity of Compass Rose Foundation, Inc. (Company) under programs of the federal government for the year ended June 30, 2025. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the Company, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Company. Basis of Accounting Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following, as applicable, either the cost principles in OMB Circular A-21, Cost Principles for Educational Institutions or the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Company has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance.
Federally guaranteed loans issued to students of the Company by financial institutions under the Federal Direct Loan (FDL) program were $4,428,478 during the year ended June 30, 2025. The amount presented represents the value of new loans awarded during the year. The Company is responsible only for the performance of certain administrative duties with respect to the FDL program and, accordingly, these loans are not included in its financial statements, and it is not practical to determine the balance of loans outstanding to students and former students of the Company under these programs at June 30, 2025.
The Company did not receive noncash assistance or have Federal insurance in effect during the fiscal year. The Company participates in the Federal Surplus Property program and received assets with a fair value of $0 in the year ended June 30, 2025.

Finding Details

FINDING 2025-001: PELL GRANT AWARD Condition In three of the forty-eight student files tested for compliance with Federal Pell Grant Program requirements, we determined the Institution miscalculated the student’s Pell award in one or more payment periods. The students involved were #s 1, 11, and 36. To gain a more accurate projection of the likely questioned costs from this finding, we expanded our testing to include another twenty-five Pell recipients and identified one student who was awarded the incorrect amount. The student’s ID number is 93547. Criteria Pell Grant awards are based on a student’s Student Aid Index (SAI), the academic year structure of the student’s educational program, and the cost of attendance (COA) for a full-time student for a full academic year. For term-based programs, awards are also based on a student’s enrollment intensity (EI). If the student does not begin attendance in all classes for a payment period, resulting in a change in the student’s EI, a school must recalculate the student’s award for that payment period based on the lower EI. Cause The students were enrolled in term-based programs. They did not attend the same number of credits that they were originally scheduled to attend (and on which their Pell payments were based), and the Institution neglected to recalculate the Pell awards and make adjustments to the student accounts. The Institution was not consistently utilizing its third-party servicer’s reports that are designed to identify these discrepancies. Effect and Questioned Costs As outlined below, the students were not paid the proper amount of Pell. Subsequent to our testing, the Institution corrected the Pell awards for each of these students. Over (Under) Student # Disbursed Eligible Award Award Year 1 $1,652 $2,465 $(813) 2024/2025 11 $2,046 $2,465 $(419) 2024/2025 36 $2,465 $1,652 $813 2024/2025 93547 $2,046 $2,465 $(419) 2024/2025 Total Questioned Costs: $2,464 The Institution disbursed a total of $387,481 to the seventy-three students in our original and expanded samples for an overall error rate of 5.5%. When applying these results to the entire population of Pell Grant recipients, we determined it is likely that questioned costs would exceed the $25,000 threshold established in 2 CFR 200.516(a)(3). Recommendation The Institution should follow its established procedures more closely to ensure that, in the future, Pell Grant awards are calculated and disbursed in accordance with the federal regulations. Views of Responsible Officials The Institution concurs with this finding.
FINDING 2025-002: LATE RETURN OF TITLE IV FUNDS Condition In four of the thirty-two student files tested for compliance with return of Title IV funds requirements, we identified a refund that was not made within the required timeframe. The students involved were #s 31, 41, 56, and 58. We expanded our return of Title IV funds testing to include all students who withdrew during the fiscal year, which included an additional one-hundred and eighty-nine (189) Title IV recipients. From this additional sample, we identified fifteen late refunds. The students’ ID numbers are 66970, 15339, 79844, 86138, 84556, 83944, 79353, 71748, 5918, 68148, 88625, 85938, 83212, 63987, and 89290. Criteria If the total amount of Title IV assistance earned by a student who has withdrawn is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. If a recipient of Title IV assistance does not begin attendance in the payment period, all disbursed Title IV funds must be returned within 30 days of the school becoming aware that the student will not or has not begun attendance. A student is considered to have not begun attendance in a payment period or period of enrollment if the school is unable to document the student’s attendance at any class during the payment period or period of enrollment. Cause The untimely return of Title IV funds appears to have resulted from procedural lapses within the Institution’s financial aid processes, as well as staff turnover in the Financial Aid Office. These factors may have contributed to gaps in oversight and delays in the consistent execution of required return procedures. The Institution didn’t have sufficient processes in place to ensure refunds were made timely when turnover occurred and or to identify when certain procedures were not being performed. Effect and Questioned Costs A Return of Title IV funds was not made in a timely manner. Details are included in Summary Schedule C of this report. As a result of this finding, the Institution has exceeded the compliance thresholds that are defined in 34 CFR 668.173(c). Recommendation The Institution should implement procedures to ensure that, in the future, Title IV refunds are made in accordance with the federal regulations. The Institution must submit an irrevocable letter of credit acceptable and payable to ED equal to 25% of the returns the Institution made during the year ended June 30, 2025. Views of Responsible Officials The Institution concurs with this finding.