2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-004 US DEPARTMENT OF EDUCATION Education Stabilization Fund CFDA# 84.425E HEERF Student Aid Portion Allowable Costs Significant Deficiency in Internal Control over Compliance Criteria: The Student Aid Portion of the Education Stabilization Fund program focuses on distributing funds to students to assist in expenses related to the pandemic and the College must have a process to reliably distribute the funds. Condition: BMCC distributes student stipends via Bank Mobile in most cases. It was found during the audit that some funds did not get fully transferred to Bank Mobile or Bank Mobile returned funds for student stipends that they were not able to get to the students. In our review of the bank reconciliations and clearing accounts during fieldwork it was found that there was about $45,000 in outstanding payments to students that had not been cashed. $26,456 of these payments were voided and not reissued and the remaining items were either just errors or were reissued to the students. Cause: Most of the funds were distributed to all eligible students as part of the College?s plan to implement the program and some students were unaware that the funds were coming and did not respond to notices in the traditional manner. The controls in place to track the outstanding items noted that there were significant funds outstanding but there was not sufficient time to follow up with each individual student. Effect: Grant expenditures and revenues related to the program were reduced and students that had initially had funds awarded had these amounts rescinded. Questioned Costs: None over the questioned cost threshold after adjustments above. Auditor?s recommendation: The College should implement additional processes to review, update, and verify student enrollment status and grant awards. Management?s response: For traditional financial aid and grant funds, awards are noted on a student award letter after verifying enrollment levels. For aid sent to students from the Education Stabilization Fund, aid awarded was not reflected on a student award letter and the aid was initially being sent to students without being requested by the student. This practice was discontinued during 2021-22 and any aid sent to students from the Education Stabilization Fund is now only done so upon request from the student. This helps to ensure students are expecting the funds and aware the funds are coming which has helped to ensure that the checks are subsequently cashed by the student or otherwise picked up by the student. In addition, as bank reconciliations are and will be done on a more timely basis, any issues with funds not getting fully transferred, or funds returned are addressed in a more timely manner.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-002 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions - Refunds Significant Deficiency in Internal Control over Compliance Criteria: A school must return unearned funds for which it is responsible as soon as possible but no later than 45 days after the date of determination of a student?s withdrawal. Condition: During our testing we found three students that officially withdrew from classes and owed refunds, but the refund to Department of Education was past the 45 day period. Cause: The College does not have an adequate process in place to notify financial aid of official withdrawals and the exceptions noted above were discovered by the college during the review of final grades, which was already past the 45 day period. The college also relies on the CNS import date as a control over these procedures but has fount that the import date is not always reliable. Effect: The College is not in compliance with the federal refund requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing but only 2 refunds were found in that testing. The College does not issue vary many refunds, so we selected 7 additional items for an infrequently operating control. Repeat Finding: No Auditor?s recommendation: We recommend the school implement a process to insure that withdrawals are communicated to financial aid immediately so they are aware of the refund calculations. Most of the refunds are for inadvertent over awards and notification of the withdrawal will assist in this issue as well. Management?s response: Students who officially withdraw from courses are required to fill out a Docusign form that is then submitted to the Academic Records department. Upon receipt of this form AR will process the withdrawal and make notes in Campus Nexus as to the date of withdraw (this is the current process as well). Financial Aid will be added to that process and those Docusign forms will be automatically forwarded to financial aid once they are processed. This way we will be able to make sure we stay within the day window for refunds. Financial aid continues to run the R2T4 report multiple times throughout the term to ensure there is plenty of time to process refunds within the 45 day mark. Additionally, our Conclusive system now has a total withdraw report available. Academic Records will give the financial aid director permission to run that report directly. The director will run this report along side the R2T4 report out of Campus Nexus to ensure we are capturing all students in a timely fashion. Students who unofficially withdraw (students who receive an FA grade at the end of the term) are not reported until the end of the term since students do have the ability to return at any time throughout the term to try and pass the class. The financial aid director has been working with the office of instruction to make sure this process is more clear and to offer trainings to faculty. We have been able to clean up the definition of an FA grade for faculty this past year, faculty have been asked to report attendance in week 9 of the quarter and this has helped with the last date of attendance reporting for Fall 2022- current term.
2022-003 US DEPARTMENT OF EDUCATION Student Financial Assistance Cluster CFDA# 84.033, 84.063, 84.007, and 84.268 Special Tests and Provisions ? Common Origination and Disbursement (COD) Reporting Significant Deficiency in Internal Control over Compliance Criteria: Institutions are required to submit disbursement records to the COD that are accurate. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition: During our testing of the information submitted to COD we noted one student out of the 40 students tested where the disbursement date per the College?s records and the processing date at COD fell outside the mandatory 15-day reporting window. Cause: The College changed student information systems and Financial Aid staff during the prior year that caused delays when the information was submitted to COD, as well as impacting the accuracy of the information being reported. Effect: The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs: None reported Context/Sampling: The College disbursed Federal financial aid to approximately 515 students in the 2021-2022 school year. A non-statistical sampling of 40 students was selected for testing. Repeat Finding: Yes Auditor?s recommendation: The College should implement additional processes to review, update, and verify student disbursements are reported to COD accurately and timely. Management?s response: The students? loans were not processed in COD (only) due to the DRI flag being set at False when in fact it should have been True because her money did disburse in April of 2022. This was an issue that was not working in CNS in Spring of 2022, the issue was fixed in CNS and we corrected the files in COD. Financial Aid performs reconciliation as required, but these students also did not show up on the reconciliation report out of CNS. This has also been fixed per Anthology.
2022-004 US DEPARTMENT OF EDUCATION Education Stabilization Fund CFDA# 84.425E HEERF Student Aid Portion Allowable Costs Significant Deficiency in Internal Control over Compliance Criteria: The Student Aid Portion of the Education Stabilization Fund program focuses on distributing funds to students to assist in expenses related to the pandemic and the College must have a process to reliably distribute the funds. Condition: BMCC distributes student stipends via Bank Mobile in most cases. It was found during the audit that some funds did not get fully transferred to Bank Mobile or Bank Mobile returned funds for student stipends that they were not able to get to the students. In our review of the bank reconciliations and clearing accounts during fieldwork it was found that there was about $45,000 in outstanding payments to students that had not been cashed. $26,456 of these payments were voided and not reissued and the remaining items were either just errors or were reissued to the students. Cause: Most of the funds were distributed to all eligible students as part of the College?s plan to implement the program and some students were unaware that the funds were coming and did not respond to notices in the traditional manner. The controls in place to track the outstanding items noted that there were significant funds outstanding but there was not sufficient time to follow up with each individual student. Effect: Grant expenditures and revenues related to the program were reduced and students that had initially had funds awarded had these amounts rescinded. Questioned Costs: None over the questioned cost threshold after adjustments above. Auditor?s recommendation: The College should implement additional processes to review, update, and verify student enrollment status and grant awards. Management?s response: For traditional financial aid and grant funds, awards are noted on a student award letter after verifying enrollment levels. For aid sent to students from the Education Stabilization Fund, aid awarded was not reflected on a student award letter and the aid was initially being sent to students without being requested by the student. This practice was discontinued during 2021-22 and any aid sent to students from the Education Stabilization Fund is now only done so upon request from the student. This helps to ensure students are expecting the funds and aware the funds are coming which has helped to ensure that the checks are subsequently cashed by the student or otherwise picked up by the student. In addition, as bank reconciliations are and will be done on a more timely basis, any issues with funds not getting fully transferred, or funds returned are addressed in a more timely manner.