Audit 387430

Finding 2025-002 – Award Requirements Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Eligibility Criteria: In accordance with 34 CFR 676.20, an institution may not award a Federal Supplemental Educational Opportunity Grant (FSEOG) for a full academic year that is less than $100 or more than $4,000. Condition: One student was found to be awarded less than $100 of FSEOG during the academic year. Cause of Condition: The College did not adhere to federal guidelines that govern FSEOG awards. Effect: The federal award amount provided to the student was not calculated in accordance with program requirements. Noncompliance with program requirements could lead to adverse consequences from the Department of Education. Questioned Costs: No questioned costs. Perspective Information: N/A Recommendation: We recommend the College ensure all staff responsible for awarding and packaging student aid are aware of the award requirements for FSEOG and that all guidance is readily available for reference when necessary.

Finding 2025-003 – COD Disbursement Records Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Reporting Criteria: In accordance with subpart G of the General Provisions regulations in 34 CFR part 668, an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement reports to COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), funds are disbursed on the date that the institution: (a) credits those funds to a student’s account in the institution’s general ledger; or (b) pays those funds to a student directly. Funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition: Two batches of Unsubsidized Direct Loan disbursement records did not agree to the applicable students’ accounts. Corrections were not made with COD to remedy these discrepancies. Cause of Condition: At the time of submissions of the disbursement records to COD, the COD system was experiencing processing issues, and these batches were not posted by COD until a number of days after the attempted submissions. This caused the incorrect dates to be posted. The College did not submit maintenance files to correct these dates to agree with students’ accounts. Effect: Failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned Costs: No questioned costs. Perspective Information: N/A Recommendation: We recommend the College review COD disbursement records after each disbursement to ensure the date agrees with student account records.

Finding 2025-004 – Enrollment Reporting (Repeat Finding) Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309, the College is required to report enrollment information under the Pell grant and the Federal Direct loan programs via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by the College. The enrollment information includes reviewing, updating, and certifying student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. Condition: Enrollment status and enrollment status effective dates are not being properly updated when a change in a student’s enrollment status occurs. An enrollment status had not been updated for a student who dropped multiple classes which resulted in a change in their enrollment status. Additionally, the wrong date was used as the effective date of the enrollment status change for another student. Cause of Condition: The College does not have a process in place to detect errors and oversights by staff. Effect: Schools are required to report accurate enrollment data to NSLDS for proper processing of student enrollment data. Changes in student enrollment statuses can affect the eligibility of Pell grants and Federal Direct loans. Improper enrollment reporting can affect the College’s enrollment reporting statistics and could lead to the College receiving compliance letters requiring remedial action. Questioned Costs: No questioned costs. Perspective Information: N/A Recommendation: We recommend that the College employ stronger oversight in this area by implementing procedures to ensure student statuses are updated correctly. Additionally, a process should be put in place to review enrollment reporting back to enrollment records to ensure accuracy.

Finding 2025-005 – Title IV Credit Balances Federal Agency: U.S. Department of Education Pass-through Entity: None Federal Program: Student Financial Assistance Cluster (Federal Assistance Listing No.’s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379) Requirement: Special Tests and Provisions Criteria: In accordance with 34 CFR 668.164(h)(2), Culver-Stockton College is required to pay, or make available, any credit balance within the 14-day regulatory timeframe when a Title IV credit balance occurs. This ensures compliance with special tests and provisions of the Uniform Guidance. Condition: During our audit, we sampled 60 students that received Title IV funds. Within that sample, we noted one student with a credit balance that the College failed to refund within the 14-day period. No authorization to retain a credit balance was obtained. Cause of Condition: The College does not have controls in place to ensure that timely refunds of credit balances occur within the 14-day period. Effect: The College is not in compliance with U.S. Department of Education regulations. Questioned Costs: No questioned costs. Perspective Information: N/A Recommendation: We recommend that internal controls be established to ensure that refunds are made available to students within a timely manner. Further, a review should be put in place to provide oversight that no accounts are missed in the refund process.