Audit 388782

Finding 2025-001: Special Tests and Provisions – NSLDS Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition: Institutions are responsible for accurately reporting all Campus-Level Record data elements and one of the Campus-Level Record data elements which ED considers to be high risk is the “Enrollment Effective Date”. Enrollment Effective Date is the date that the current enrollment status reported for a student was first effective. For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. Additionally, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Cause: Lack of precision in the review of reporting of Enrollment Effective Dates to the NSLDS as well as the review of the consistency of information between NSLDS and the College’s internal records, before submission. Effect: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, the effective date per internal College records did not match NSLDS. Questioned Costs: None. Context: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. This student was noted per the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately as Program-Level Enrollment data indicated this student as being withdrawn but the Campus-Level Enrollment data did not. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was followed, but the Date per College records did not match that of NSLDS. Repeat Finding: No. Recommendation: It is recommended that the College enhances the precision of its review of both categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types which are accurate and do not contradict each other. Views of Responsible Officials: In response, the College implemented standardized processes for processing LOA and withdrawal actions. This documentation provides a framework for staff to ensure that effective dates per the College are aligned with what is transmitted to the NSLDS. Additionally, the College revised its reporting schedule to ensure that LOA and withdrawal updates are transmitted on a regular, recurring basis. Refer to the Corrective Action Plan for Current Year Findings.

Finding 2025-002: Eligibility Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Criteria: 34 CFR 668.42, 34 CFR 673.5, 34 CFR 673.6, and 34 CFR 685.301 require institutions to ensure that aid awarded to students does not exceed the student’s financial need or cost of attendance (COA). The determination of need-based award amounts is based on financial need. Financial need is defined as the student’s COA minus the student’s student aid index (“SAI”). In accordance with the FAFSA Simplification Act, which included a set of changes to the Free Application for Federal Student Aid (“FAFSA”) aimed at making the process easier and more accessible by reducing the number of questions and simplifying the financial aid calculation formula, the new SAI amount replaced the Expected Family Contribution (“EFC”). SAI is computed by the FAFSA processing system (“FPS”) and is included on the student’s FAFSA submission. To avoid any overpayments, need-based awards cannot exceed the student’s overall financial need. Condition: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the initial calculation by the College of the student’s SAI. This was the result of a change in the student’s enrollment intensity which was not properly captured in the calculation of PELL aid. Cause: The College’s manual review of the PELL award calculation under the reprocessed FAFSA for this student was not precise enough to properly identify changes in the student’s enrollment intensity during the period as part of the calculation of the PELL award. Effect: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the initial calculation by the College of the student’s SAI. This was the result of a change in the student’s enrollment intensity which was not properly captured in the calculation of PELL aid. Questioned Costs: N/A Context: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the calculation by the College of the student’s SAI and enrollment intensity. The student was under-awarded PELL based on a change in enrollment intensity during the semester which was not accurately captured in the College’s reprocessing of the student ISIR form as part of the College’s implementation of the FAFSA Simplification Act. Repeat Finding: No. Recommendation: It is recommended that the College conduct a precise review of student enrollment intensity changes throughout the award disbursement process to ensure that they do not result in errors in the calculations and disbursement of aid. Views of Responsible Officials: In response, the College implemented further reporting enhancements to ensure that all awards are accurate. This includes generating the following reports for further review and analysis: all student actions following the Add/Drop period until mid-semester, Pell-only students who are less than full-time at the end of the Add/Drop period, and weekly student enrollment intensity changes. Refer to the Corrective Action Plan for Current Year Findings.

Finding 2025-003: Cash Management Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Criteria: In accordance with 2 CFR 200.305 (b)(3) and per the terms of the underlying grant agreements, the College is funded under the reimbursement method and therefore, cash drawdowns/reimbursement requests made during the period from the federal agency or pass-through entity should be for expenditures incurred prior to the date of the reimbursement request. Condition: While reimbursement requests submitted by the College were for expenditures incurred prior to the date of the reimbursement requests, certain reimbursement requests were not submitted within the specific time frames and with the requisite documentation required per the grant agreements. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for reimbursement requests per the grant agreements. Effect: While reimbursement requests submitted by the College were for expenditures incurred prior to the date of the reimbursement requests, certain reimbursement requests were not submitted within the specific time frames and with the requisite documentation required per the grant agreements. Questioned Costs: None. Context: Final reimbursement request for the “I Can Connect (ICC)” grant was not submitted within 12 days of the grant end date as indicated in the initial grant agreement. Final reimbursement request for the “I Can Connect (ICC)” grant was due by July 19, 2025 but it was not submitted until November 17, 2025. The reimbursement requests were missing certain required documentation elements outlined in the underlying grant agreements. Repeat Finding: No. Recommendation: It is recommended that management conduct a more thorough review of the grant agreements to ensure that all timing and supporting documentation requirements are met as they relate to reimbursement requests submitted to granting agencies. Views of Responsible Individuals: In response, the College strengthened control processes as it relates to reimbursement processing, including enhanced month-end procedures, hiring a staff member for additional oversight, strengthening communication, and establishing a grant-specific reimbursement tracker. In addition, a mandatory annual training will be implemented beginning in fiscal year 2026. Refer to the Corrective Action Plan for Current Year Findings.

Finding 2025-004: Reporting Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Criteria: Award recipients, as dictated by the grant agreements, may be required to provide performance reporting to the awarding agency in order to maintain funding. For performance reporting, non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly using a form or format authorized by the awarding agency (2 CFR 200.329). Condition: In accordance with the grant agreements, the College was required to provide certain quarterly and annual performance reports which were not submitted timely. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for periodic performance reporting per the grant agreements. Effect: Certain performance reports were not submitted timely in accordance with the requirements of the respective grant agreements. Questioned Costs: None. Context: For the “Transition TA & Administration” and “Summer Transition Programs” grants, the College was unable to produce evidence that performance reporting occurred timely and with the requisite approvals. Repeat Finding: No. Recommendation: It is recommended that management perform a more thorough review of specific reporting requirements related to the ALN 84.126A grant agreements to ensure that the College’s requirements as they relate to performance reporting requirements are met. Views of Responsible Individuals: In response, the College is looking to implement a centralized reporting and tracking system with reminders for deadlines as well as incorporating reviews over performance reporting into month-end procedures. Oversight over reporting has been added as part of the monthly Research Administration meetings, and the College is looking to expand support staff to assist with performance monitoring. Lastly, the College is planning to expand annual training requirements for all principal investigators and support staff. Refer to the Corrective Action Plan for Current Year Findings.