Audit 38278

FINDING NO. 2022-001: Ineligible Disbursement ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A dependent student was awarded a Federal Unsubsidized Direct Loan without documentation of a parent loan denial. Criteria Federal Unsubsidized Direct Loans are only available to dependent students when a loan to the student?s parents (PLUS) is denied or the file contains documentation of parents? inability to repay the parent loan. 34 CFR 685.203. Effect Of 76 files tested, 1 dependent student received a Federal Direct Unsubsidized Loan in the amount of $1,979 without appropriate documentation. The student was properly awarded all other aid received as a dependent student. Total questioned costs are $1,979. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, the Institution did not follow its procedures in properly making awards to students based on federal dependency status criteria. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.

FINDING NO. 2022-002: Late Refunds ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV Funds payment for one student was not made in a timely manner. Criteria The U.S. Department of Education requires that refunds made electronically under the Return to Title IV Funds provisions be returned within 45 days of a student?s official withdrawal date to be considered timely. (34 CFR 668.22.) Effect A Return of Title IV Funds payment was not paid within the required time frame for 1 of the 31 student files tested for refund compliance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. The late payment associated with this finding is: Amount of Refund Program Paid Withdrawal Date Refund Due Date Refund Date Days Late $ 818 FDLP 11/4/21 1/6/22 1/25/22 19 Cause In this instance of noncompliance, the Institution?s internal control did not function as designed and therefore the Institution?s procedures for processing refunds and Return of Title IV Funds payments were not followed. Recommendation The Institution should take steps to ensure that its procedures for the timely disbursement of refunds and Returns of Title IV Funds payments are strictly followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.

FINDING NO. 2022-003: Refunds Not Performed ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV funds calculation was not performed when a student withdrew from an instructional program. Criteria Refunds for withdrawn students are to be properly calculated in accordance with applicable refund policies. 34 CFR 668.22. Effect Of 31 files tested for refund compliance, a Return to Title IV Funds calculation was not performed for 1 student at the time of withdrawal. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, procedures to ensure the proper completion of refund calculations and appropriate payment of resulting refunds due were not followed. Recommendation Due diligence and care must be exercised in completing refund calculations in accordance with SFA program requirements. Additional Information Upon learning of this finding, the Institution performed the Return of Title IV Funds calculation for the student. The calculation resulted in refunds due in the amounts of $1,485 to the student?s Federal Subsidized Direct Loan, $1,979 to the student?s Federal Unsubsidized Direct Loan, and $1,491 to the Federal Pell Grant Program. We reviewed the refund calculation and the return of funds documentation and found them accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.

FINDING NO. 2022-001: Ineligible Disbursement ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A dependent student was awarded a Federal Unsubsidized Direct Loan without documentation of a parent loan denial. Criteria Federal Unsubsidized Direct Loans are only available to dependent students when a loan to the student?s parents (PLUS) is denied or the file contains documentation of parents? inability to repay the parent loan. 34 CFR 685.203. Effect Of 76 files tested, 1 dependent student received a Federal Direct Unsubsidized Loan in the amount of $1,979 without appropriate documentation. The student was properly awarded all other aid received as a dependent student. Total questioned costs are $1,979. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, the Institution did not follow its procedures in properly making awards to students based on federal dependency status criteria. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.

FINDING NO. 2022-002: Late Refunds ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV Funds payment for one student was not made in a timely manner. Criteria The U.S. Department of Education requires that refunds made electronically under the Return to Title IV Funds provisions be returned within 45 days of a student?s official withdrawal date to be considered timely. (34 CFR 668.22.) Effect A Return of Title IV Funds payment was not paid within the required time frame for 1 of the 31 student files tested for refund compliance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. The late payment associated with this finding is: Amount of Refund Program Paid Withdrawal Date Refund Due Date Refund Date Days Late $ 818 FDLP 11/4/21 1/6/22 1/25/22 19 Cause In this instance of noncompliance, the Institution?s internal control did not function as designed and therefore the Institution?s procedures for processing refunds and Return of Title IV Funds payments were not followed. Recommendation The Institution should take steps to ensure that its procedures for the timely disbursement of refunds and Returns of Title IV Funds payments are strictly followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.

FINDING NO. 2022-003: Refunds Not Performed ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV funds calculation was not performed when a student withdrew from an instructional program. Criteria Refunds for withdrawn students are to be properly calculated in accordance with applicable refund policies. 34 CFR 668.22. Effect Of 31 files tested for refund compliance, a Return to Title IV Funds calculation was not performed for 1 student at the time of withdrawal. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, procedures to ensure the proper completion of refund calculations and appropriate payment of resulting refunds due were not followed. Recommendation Due diligence and care must be exercised in completing refund calculations in accordance with SFA program requirements. Additional Information Upon learning of this finding, the Institution performed the Return of Title IV Funds calculation for the student. The calculation resulted in refunds due in the amounts of $1,485 to the student?s Federal Subsidized Direct Loan, $1,979 to the student?s Federal Unsubsidized Direct Loan, and $1,491 to the Federal Pell Grant Program. We reviewed the refund calculation and the return of funds documentation and found them accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.