Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of whether they receive aid from the institution. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: Of the 33 students selected for testing, 12 students had errors in enrollment status; the institution's records did not match what was reported to NSLDS. We also noted one student tested did not have enrollment data certified at least every 60 days as required. Additionally, one student’s enrollment begin date per the institution’s records did not agree to NSLDS records. Questioned Costs: None Context: During our testing, we noted the College did not have proper procedures in place to verify the reports sent to NSLDS are timely and accurate. Cause: The College processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should reflect the student's last date of attendance and academically-related activity. In addition, students’ enrollment status should be certified every 60 days and the program begin date should be the first day attended at the College. Effect or Potential Effect of Finding: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, see finding 2024-001. Recommendation: We recommend the College review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Material Weakness in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, and FWS. Likewise, the College did not have a formal review of their award packaging during the 2024-25 academic year, R2T4 calculations, direct payment of FSA credit balances to students, and FISAP. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2024-25 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had limited personnel in the financial aid department in order to maintain proper segregation of duties. Effect or Potential Effect of Finding: The College is not in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: Yes, see finding 2024-002. Recommendation: We recommend the College review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR §668.22(j), states institutions must return Title IV funds to the U.S. Department of Education within 45 days of the date the institution determines that the student withdrew. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), also states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing of Return of Title IV (R2T4) calculations, we noted that 2 of 12 students tested did not have funds returned to the Common Origination and Disbursement (COD) system within the required 45-day timeframe after the R2T4 calculation was completed. Additionally, during our testing, we noted for 1 of the 12 individuals tested, the College had used an incorrect percentage of days attended causing the College to incorrectly calculate the return of Title IV funds. Questioned Costs: $417 Context: Federal regulations require institutions to calculate and return unearned Title IV funds when a student withdraws. The calculation is based on the percentage of days attended, and funds must be returned to the COD system within 45 days of completing the R2T4 calculation. These rules ensure compliance with U.S. Department of Education requirements and protect federal funds. Cause: The College did not have a process in place to timely return funds to the Department of Education as well as correctly calculate the students’ percentage of days attended. Effect or Potential Effect of Finding: The College is not completing accurate R2T4 calculations as defined by the regulations. Failure to return funds timely may result in noncompliance with federal regulations, potential liabilities, and risk of loss of eligibility for Title IV programs. Repeat Finding: Yes, see finding 2024-006. Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure that calculations use the correct number of break days and are completed accurately and within the required timeframes. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement scheduled published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student’s SAI, and the enrollment status of the student. Condition: During our testing, we noted 1 of the 40 students selected for eligibility testing were under-awarded Pell for the fiscal year due to a manual packaging error during the year. Questioned Costs: None Context: Pell Grant awards are determined based on federal eligibility criteria and must be accurately packaged to ensure students receive the correct amount of aid. Manual errors in the packaging process can lead to under-awards or over-awards, resulting in noncompliance with U.S. Department of Education regulations and potential financial impact for students and the institution. Cause: The Pell grant was manually repackaged during the year when a student withdrew from a class causing an error in the amount awarded. Effect or Potential Effect of Finding: Students were under-awarded Pell funds. Repeat Finding: Yes – see finding 2024-005. Recommendation: We recommend the College implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR §690.83 and COD reporting requirements require institutions to accurately report Pell Grant disbursement dates to the COD system to ensure compliance with federal regulations. Condition: During testing of Pell Grant disbursements, we noted that 6 of the 40 students tested had incorrect Pell disbursement dates reported to the COD system. Questioned Costs: None Context: Federal regulations require institutions to accurately report Pell Grant disbursement dates to the COD system. These dates are critical for tracking compliance and ensuring proper administration of Title IV funds. Incorrect reporting can lead to discrepancies in federal records and potential compliance issues with U.S. Department of Education requirements. Cause: The College did not have a process in place to ensure Pell Grant disbursement information was being accurately reported to the COD system. Effect or Potential Effect of Finding: Incorrect reporting of Pell disbursement dates may result in noncompliance with federal regulations, potential audit findings, and risk of inaccurate student financial aid records. Repeat Finding: No. Recommendation: We recommend the College establish a process to ensure that all disbursement information is accurately reported to the COD system. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. Title IV, HEA credit balances must be paid directly to the student or parent as soon as possible, but: (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted that although the refunds were ultimately paid, 8 out of 40 credit balances tested were not refunded within the required 14-day period. Questioned Costs: None Context: Federal regulations require institutions to refund credit balances resulting from Title IV funds within 14 days of the balance being created. Timely refunds ensure compliance with U.S. Department of Education requirements and protect students from delays in receiving funds. Failure to meet this deadline can result in noncompliance and potential financial or administrative consequences. Cause: The College did not have proper procedures in place to ensure all credit balances are refunded within the 14-day period. Effect or Potential Effect of Finding: The College did not refund students within 14 days for credit balances that arose from federal funds as required by the regulations. Repeat Finding: Yes, see finding 2024-009. Recommendation: We recommend the College review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.16 and volume 4 states that, at a minimum, the College should reconcile its FSA financial records monthly and should be conducted on a more frequent basis during periods of high transaction volume. Condition: During our testing, we noted there was no formal process in place for reconciling and reviewing the Nursing Student Loan (NSL) and Nurse Faculty Loan Program (NFLP) balances on a regular basis. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2024-25 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: Due to an ongoing reconciling difference with the loan servicer, the College was not able to perform timely reconciliations. Effect or Potential Effect of Finding: Timely reconciliations and adequate review of financial transactions can protect the College’s assets and ensure the accounting records are accurate. Repeat Finding: Yes, see finding 2024-007. Recommendation: We recommend the College provide all necessary employees with training, support, and sufficient time to follow College policies and federal requirements related to monthly reconciliations. Views of Responsible Officials: There is no disagreement with the audit finding.