Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-003: Significant Deficiency - Enrollment Reporting Program: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P063P21186 and P268K221186 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of August 20, 2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. The sample was not a statistically valid sample. Cause: The College noted the reporting was completed timely to the servicer National Student Clearinghouse (NSC) however was not reflected in NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. In order to ensure compliance in 2022-2023, the Office of the Registrar has increased degree reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60 day file requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by the College to NSC.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-005: Significant Deficiency ? Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Program: Education Stabilization Fund Assistance Listing Number: 84.425 E, F and L Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200371, P425F201133, and P425L200166 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion, and one containing both institutional and student portion reporting, it was noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - For quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. The sample of reports tested was not a statistically valid sample. Cause: The College?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the incorrect and untimely HEERF reporting. Effect: The College was not in compliance with the HEERF quarterly reporting requirements. Questioned costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: Management acknowledges the finding. The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. The College reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. The College has completed all quarterly filings for HEERF funds as they have all been spent. The final annual HEERF report for calendar year 2022 will be filed accurately and on time.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-005: Significant Deficiency ? Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Program: Education Stabilization Fund Assistance Listing Number: 84.425 E, F and L Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200371, P425F201133, and P425L200166 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion, and one containing both institutional and student portion reporting, it was noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - For quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. The sample of reports tested was not a statistically valid sample. Cause: The College?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the incorrect and untimely HEERF reporting. Effect: The College was not in compliance with the HEERF quarterly reporting requirements. Questioned costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: Management acknowledges the finding. The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. The College reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. The College has completed all quarterly filings for HEERF funds as they have all been spent. The final annual HEERF report for calendar year 2022 will be filed accurately and on time.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-005: Significant Deficiency ? Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Program: Education Stabilization Fund Assistance Listing Number: 84.425 E, F and L Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200371, P425F201133, and P425L200166 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion, and one containing both institutional and student portion reporting, it was noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - For quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. The sample of reports tested was not a statistically valid sample. Cause: The College?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the incorrect and untimely HEERF reporting. Effect: The College was not in compliance with the HEERF quarterly reporting requirements. Questioned costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: Management acknowledges the finding. The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. The College reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. The College has completed all quarterly filings for HEERF funds as they have all been spent. The final annual HEERF report for calendar year 2022 will be filed accurately and on time.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Program: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221186 Federal Award Year: June 30, 2022 Criteria: Title IV regulations note that Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). The U.S. Department of Education released an electronic announcement December 18, 2020 reminding institutions of this requirement. Each month, Common Origination and Disbursement (COD) provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. At a minimum, this reconciliation must be completed at least monthly to ensure that data is correct in all systems and that cash management and disbursement reporting timelines are being met. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month. Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution regarding review of the reconciliations by someone other than the preparer occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Cause: The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the monthly reconciliations not being performed timely. Effect: The information in the College?s system or data reported to COD may be incorrect and not correctly timely if the monthly reconciliations are not occurring. Questioned costs: $177,816 of Federal Direct Loans assistance listing number 84.268. Recommendation: It is recommended that the College review staffing and policies and procedures to ensure that the monthly direct loan reconciliation is completed in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. For the $177,816 in direct loans incorrectly disbursed that was identified, the College returned the loans and replaced with institutional aid for the impacted students. The Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been set up for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tracts Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Director for review.
Finding 2022-003: Significant Deficiency - Enrollment Reporting Program: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P063P21186 and P268K221186 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of August 20, 2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. The sample was not a statistically valid sample. Cause: The College noted the reporting was completed timely to the servicer National Student Clearinghouse (NSC) however was not reflected in NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. In order to ensure compliance in 2022-2023, the Office of the Registrar has increased degree reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60 day file requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by the College to NSC.
Finding 2022-004: Significant Deficiency - Non-compliance with Reporting Requirements for Disbursements Program: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221186 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-003 Criteria: Title IV regulations, including the most recent Federal Register Notice, published in June 2021, specifies that a school must submit disbursement records no later than 15 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement. Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. The US Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. At the time an institution makes a disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). For students and/or parents receiving direct loans for the first time they are required to completed entrance counseling and sign the master promissory note. Condition/Context: For 2 of 25 students selected for testing, the disbursement dates did not agree between the student?s institutional account and the data reported to COD. The students had disbursements that were later refunded. It was noted that the students were disbursed without a valid MPN on file, resulting in students being disbursement that were not eligible at the time of disbursement. The College ultimately obtained the signed valid MPNs and then re-disbursed the funds, as a result the student account original disbursement date and the COD disbursement date differ. The sample was not a statistically valid sample. Cause: The College failed to follow its procedures for ensuring students were eligible prior to disbursing funds. Effect: The College disbursed Title IV funds to students that were not eligible for aid at the time of disbursement. Questioned costs: $29,410 of Federal Direct Plus Loans assistance listing number 84.268. Recommendation: It is recommended that the College update policies and procedures for ensuring students are eligible prior to disbursing funds to ensure compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. To ensure that this problem does not recur for 2022-2023, disbursement rules have been instituted in Colleague that would prevent funds disbursing if a student hasn?t completed an MPN. The frequency of exports from Colleague to COD has been increased. In addition, Direct Loan and Pell rejects are being corrected each week so that if funds are disbursed and a Colleague or COD error is received, the disbursement is corrected and re-exported before the 15-day time limit.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-003: Significant Deficiency - Enrollment Reporting Program: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P063P21186 and P268K221186 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of August 20, 2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. The sample was not a statistically valid sample. Cause: The College noted the reporting was completed timely to the servicer National Student Clearinghouse (NSC) however was not reflected in NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. In order to ensure compliance in 2022-2023, the Office of the Registrar has increased degree reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60 day file requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by the College to NSC.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-005: Significant Deficiency ? Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Program: Education Stabilization Fund Assistance Listing Number: 84.425 E, F and L Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200371, P425F201133, and P425L200166 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion, and one containing both institutional and student portion reporting, it was noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - For quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. The sample of reports tested was not a statistically valid sample. Cause: The College?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the incorrect and untimely HEERF reporting. Effect: The College was not in compliance with the HEERF quarterly reporting requirements. Questioned costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: Management acknowledges the finding. The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. The College reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. The College has completed all quarterly filings for HEERF funds as they have all been spent. The final annual HEERF report for calendar year 2022 will be filed accurately and on time.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-005: Significant Deficiency ? Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Program: Education Stabilization Fund Assistance Listing Number: 84.425 E, F and L Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200371, P425F201133, and P425L200166 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion, and one containing both institutional and student portion reporting, it was noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - For quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. The sample of reports tested was not a statistically valid sample. Cause: The College?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the incorrect and untimely HEERF reporting. Effect: The College was not in compliance with the HEERF quarterly reporting requirements. Questioned costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: Management acknowledges the finding. The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. The College reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. The College has completed all quarterly filings for HEERF funds as they have all been spent. The final annual HEERF report for calendar year 2022 will be filed accurately and on time.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-005: Significant Deficiency ? Education Stabilization Fund ? Higher Education Emergency Relief Fund - Reporting Program: Education Stabilization Fund Assistance Listing Number: 84.425 E, F and L Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200371, P425F201133, and P425L200166 Federal Award Year: June 30, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Condition/Context: For three of the four quarterly reports selected for testing, two for the student portion, and one containing both institutional and student portion reporting, it was noted that some of the information reported did not agree to the support provided, two of those reports also did not agree to the drawdowns from G5, two of those reports had required information missing, and two of those reports were posted late. ? Student portion report - for quarter three of calendar year 2021 the amount of emergency grants to students of $1,133,392 did not agree to the underlying support of $1,078,437 or drawdowns from G5 of $954,932. The number of eligible students and the number of students who received an emergency financial aid grant were missing from the report. ? Student portion report - for quarter four of calendar year 2021 the amount of emergency grants to students of $1,745,664 did not agree to the underlying support of $1,735,664 or drawdowns from G5 of $1,902,140. The number of eligible students was missing from the report. The report was posted to the Institution's website on January 24, 2022 after the required deadline of January 10, 2022. ? Combined report - For quarter one of calendar year 2022 the amount of emergency grants to students of $405,000 was reported for the institutional portion of HEERF but should have been for the student portion, the same amount was also reported for the institutional portion as covering student outstanding account balances and lost revenue. The report was posted to the Institution's website on July 8, 2022 after the required deadline of April 10, 2022. The report for quarter two of calendar year 2022 report was not submitted timely and was in process during the audit and therefore, was not selected for testing. The annual report had several items that did not agree to the underlying support. How many students received HEERF emergency financial aid grants, amount disbursed directly to students for emergency financial aid grants, amount of grants disbursed to students from all HEERF funds, total institutional funds used did not include amounts for room and board refunds that were reported in quarterly reporting during calendar 2021. The sample of reports tested was not a statistically valid sample. Cause: The College?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late posting of the quarterly reports to the University?s website. The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the incorrect and untimely HEERF reporting. Effect: The College was not in compliance with the HEERF quarterly reporting requirements. Questioned costs: Not applicable. Recommendation: The College should ensure it keeps up to date on the Department?s HEERF guidance and ensure that reporting is done accurately and timely. Management?s Response: Management acknowledges the finding. The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees regarding how to report expenses for HEERF. The College reached out to the Department of Education and alerted them to the late filing of the reports and received acknowledgment of the late filings. The College has completed all quarterly filings for HEERF funds as they have all been spent. The final annual HEERF report for calendar year 2022 will be filed accurately and on time.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.
Finding 2022-001: Significant Deficiency - Return of Title IV Funds Program: Student Financial Assistance Cluster Assistance Listing Number: 84.007 Federal Agency: U.S. Department of Education Federal Award Identification Number: P007A210558 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-001 Criteria: Title IV regulations (34 CFR 668.22) require the College to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re-disbursed before the R2T4 calculation and return occurred. The sample was not a statistically valid sample. Questioned Costs: A total of $375 in Federal Supplemental Educational Opportunity Grant assistance listing number 84.007. Cause: The College experienced significant staffing issues/changes in key positions in the student financial aid office and changes to procedures for the return of Title IV funds were not completed until well into the 2021-22 year when the prior single audit with finding was completed. Effect: The College returned incorrect amounts to students and/or the US Department of Education and they were in possession of funds belonging to the federal government longer than allowed. Recommendation: The College should continue to review and adhere to its procedures for refunding awards and implement a more rigorous review process, to ensure withdrawal listings are complete, refunds are calculated correctly and timely and any returns are made within the required timeframe. Management?s Response: Management acknowledges the finding. Subsequent to the 2021-2022 single audit, the College had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed.
Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Program: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221186 Federal Award Year: June 30, 2022 Criteria: Title IV regulations note that Direct Loan reconciliation is a mandatory monthly process, as required under 34 CFR 685.300(b)(5). The U.S. Department of Education released an electronic announcement December 18, 2020 reminding institutions of this requirement. Each month, Common Origination and Disbursement (COD) provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. At a minimum, this reconciliation must be completed at least monthly to ensure that data is correct in all systems and that cash management and disbursement reporting timelines are being met. Since up to three Direct Loan program years may be open at any given time, institutions may receive three SAS data files each month. Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution regarding review of the reconciliations by someone other than the preparer occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Cause: The College noted there was significant staffing issues/changes in key positions in the student financial aid office and business office and that resulted in the monthly reconciliations not being performed timely. Effect: The information in the College?s system or data reported to COD may be incorrect and not correctly timely if the monthly reconciliations are not occurring. Questioned costs: $177,816 of Federal Direct Loans assistance listing number 84.268. Recommendation: It is recommended that the College review staffing and policies and procedures to ensure that the monthly direct loan reconciliation is completed in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. For the $177,816 in direct loans incorrectly disbursed that was identified, the College returned the loans and replaced with institutional aid for the impacted students. The Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been set up for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tracts Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Director for review.
Finding 2022-003: Significant Deficiency - Enrollment Reporting Program: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P063P21186 and P268K221186 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of August 20, 2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. The sample was not a statistically valid sample. Cause: The College noted the reporting was completed timely to the servicer National Student Clearinghouse (NSC) however was not reflected in NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an Institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned costs: Not applicable Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. In order to ensure compliance in 2022-2023, the Office of the Registrar has increased degree reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60 day file requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by the College to NSC.
Finding 2022-004: Significant Deficiency - Non-compliance with Reporting Requirements for Disbursements Program: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K221186 Federal Award Year: June 30, 2022 Repeat of prior year finding 2021-003 Criteria: Title IV regulations, including the most recent Federal Register Notice, published in June 2021, specifies that a school must submit disbursement records no later than 15 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement. Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. The US Department of Education processes origination and/or disbursement records and returns acknowledgments to the institution. At the time an institution makes a disbursement to a student, it must confirm that the student is eligible for the funds being disbursed (34 CFR 668.164(b)(3)). For students and/or parents receiving direct loans for the first time they are required to completed entrance counseling and sign the master promissory note. Condition/Context: For 2 of 25 students selected for testing, the disbursement dates did not agree between the student?s institutional account and the data reported to COD. The students had disbursements that were later refunded. It was noted that the students were disbursed without a valid MPN on file, resulting in students being disbursement that were not eligible at the time of disbursement. The College ultimately obtained the signed valid MPNs and then re-disbursed the funds, as a result the student account original disbursement date and the COD disbursement date differ. The sample was not a statistically valid sample. Cause: The College failed to follow its procedures for ensuring students were eligible prior to disbursing funds. Effect: The College disbursed Title IV funds to students that were not eligible for aid at the time of disbursement. Questioned costs: $29,410 of Federal Direct Plus Loans assistance listing number 84.268. Recommendation: It is recommended that the College update policies and procedures for ensuring students are eligible prior to disbursing funds to ensure compliance with Title IV regulations. Management?s Response: Management acknowledges the finding. To ensure that this problem does not recur for 2022-2023, disbursement rules have been instituted in Colleague that would prevent funds disbursing if a student hasn?t completed an MPN. The frequency of exports from Colleague to COD has been increased. In addition, Direct Loan and Pell rejects are being corrected each week so that if funds are disbursed and a Colleague or COD error is received, the disbursement is corrected and re-exported before the 15-day time limit.
Finding 2022-006: Significant Deficiency ? Control Environment Program: Student Financial Assistance Cluster and Higher Education Emergency Relief Funds Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Cause: During the audit, it was noted that there was significant turnover in key positions responsible for administering the federal awards programs. Effect: The College had several compliance and controls findings reported for the year ended June 30, 2022. Questioned costs: Not determinable Recommendation: The College should review all process, policies and procedures around federal awards programs to ensure adequate staffing, staff experience and continuing education and a system of internal controls are in place in order to comply with federal regulations and compliance requirements. Management?s Response: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened.