Audit 38022

FY End
2022-12-31
Total Expended
$2.65M
Findings
2
Programs
9
Year: 2022 Accepted: 2023-07-13

Organization Exclusion Status:

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Contacts

Name Title Type
DUV8VM6Y9ZD1 Laurie Tharpe Auditee
4784714858 Bonnie Cox Auditor
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Notes to SEFA

Title: Note 4: Noncash awards Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting method. Under this basis, expenses are recognized when incurred. This method is consistent with the method used to prepare the basic combined financial statements. 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. Cost Principles - The cost principles applicable to the expenditures on the Schedule include Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These principles identify certain types of expenditures that are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The Organization has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Organization did not receive noncash federal awards during the year ended December 31, 2022.
Title: Note 1: Basis of presentation Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting method. Under this basis, expenses are recognized when incurred. This method is consistent with the method used to prepare the basic combined financial statements. 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. Cost Principles - The cost principles applicable to the expenditures on the Schedule include Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These principles identify certain types of expenditures that are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The Organization has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal award activity of Goodwill Industries of Middle Georgia, Inc. and Affiliates (the "Organization") and 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").
Title: Note 3: Subrecipients Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting method. Under this basis, expenses are recognized when incurred. This method is consistent with the method used to prepare the basic combined financial statements. 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. Cost Principles - The cost principles applicable to the expenditures on the Schedule include Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These principles identify certain types of expenditures that are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The Organization has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Organization did not provide federal awards to subrecipients during the year ended December 31, 2022.
Title: Note 5: State funds Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting method. Under this basis, expenses are recognized when incurred. This method is consistent with the method used to prepare the basic combined financial statements. 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. Cost Principles - The cost principles applicable to the expenditures on the Schedule include Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These principles identify certain types of expenditures that are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The Organization has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The state of Georgia receives awards directly from the federal government and supplements those funds with its own funds. The state then awards a combination of federal and state funds to the Organization. If the Organization is unable to determine the federal portion, the entire amount is reported on the Schedule of Expenditures of Federal Awards.
Title: Note 6: Contingencies Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting method. Under this basis, expenses are recognized when incurred. This method is consistent with the method used to prepare the basic combined financial statements. 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. Cost Principles - The cost principles applicable to the expenditures on the Schedule include Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These principles identify certain types of expenditures that are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The Organization has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. These programs are subject to financial and compliance audits by grantor agencies. The amount, if any, of expenditures that may be disallowed by the grantor agencies cannot be determined at this time, although the Organization expects such amounts, if any, to be immaterial.
Title: Note 7: Higher Education Emergency Relief Fund Accounting Policies: Basis of Accounting - Expenditures reported on the Schedule are reported on the accrual basis of accounting method. Under this basis, expenses are recognized when incurred. This method is consistent with the method used to prepare the basic combined financial statements. 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. Cost Principles - The cost principles applicable to the expenditures on the Schedule include Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These principles identify certain types of expenditures that are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: Indirect Cost Rate - The Organization has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. The Coronavirus Aid, Relief, and Economic Security Act created a Higher Education Emergency Relief Fund ("HEERF") to provide financial relief to students and institutions who were impacted by the COVID-19 pandemic. The Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and the America Rescue Plan (ARP) provided additional rounds of HEERF (II and III). The HEERF funds contained two components, an institutional award and a student aid award. The following cumulative amounts have been awarded as HEERF as of December 31, 2022: See Notes to the SEFA for Chart/table. The Organization expended the following funds for the year ended December 31, 2022: See Notes to the SEFA for Chart/table.

Finding Details

Finding 2022-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS?). Enrollment status changes for students must 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. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: - Four (4) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Four (4) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Twelve (12) began attending the School in 2022, but were not reported prior to the NSLDS outage beginning in July 2022. QUESTION COSTS: None noted. CAUSE: The School did not implement the corrective action plan from the prior year audit until February 2023. Further, the NSLDS was down from July 2022 to February 2023 and as such, the new policies did not fully take effect until after the year-end. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar?s Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government?s NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the NSLDS became available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule.
Finding 2022-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS?). Enrollment status changes for students must 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. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: - Four (4) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Four (4) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Twelve (12) began attending the School in 2022, but were not reported prior to the NSLDS outage beginning in July 2022. QUESTION COSTS: None noted. CAUSE: The School did not implement the corrective action plan from the prior year audit until February 2023. Further, the NSLDS was down from July 2022 to February 2023 and as such, the new policies did not fully take effect until after the year-end. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar?s Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government?s NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the NSLDS became available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule.