Ineligible Student Received Title IV funding Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242049, P033A242049, P063P241644, P063Q241644 and P268K251644. Criteria. Title 34 of the Code of Federal Regulations (34 CFR 668.34) requires institutions to establish and apply a reasonable Satisfactory Academic Progress (SAP) policy to determine whether an otherwise eligible student is making sufficient academic progress to continue receiving Title IV, HEA program assistance. Condition. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. Cause. A review was not performed to determine whether the prior appeal remained valid or whether the student had demonstrated sufficient academic progress to qualify for Title IV aid in the Spring 2024–2025 semester. Effect. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Fiscal Operations Report and Application to Participate (FISAP) Reporting (repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242049, P033A242049, P063P241644, P063Q241644 and P268K251644. Criteria. The Code of Federal Regulations, 34 CFR 675.19(b)(3) states that accurate information be populated and submitted on the Fiscal Operations Report and Application to Participate (FISAP). Condition. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the compliance supplement as critical information. Cause. The College does not have policies and procedures in place to ensure information reported on the FISAP was accurate. Effect. As a result, the College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs. Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Cost of Attendance Calculation Inputs (repeat finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242049, P033A242049, P063P241644, P063Q241644 and P268K251644. Criteria. In accordance with 34 CFR 668.42 (FWS), 34 CFR 673.5 and 673.6 (FSEOG), and 34 CFR 685.301 (Direct Loan), as referenced in the Compliance Supplement, total Title IV aid awarded to a student may not exceed the student’s financial need or cost of attendance (COA). Institutions must ensure that COA components are accurately determined and consistently applied. Condition. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calculation sheet. For instance, the College's tuition component was supposed to be based on credit intensity, but instead was being calculated using the student's enrollment status (e.g., full-time, half-time, etc.). Additionally, the College included direct loan fees in every students COA, even if they were not a direct loan receiving student. Cause. The College does not have a review process in place for ensuring the inputs used in the cost of attendance determination are accurate. Effect. As a result, COA amounts used in awarding Title IV aid were being understated, preventing some students from potentially receiving additional aid they were entitled to. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College establish and adhere to review procedures to ensure that all inputs used in the COA calculation are accurate, complete, and consistent with approved documentation. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Student Credit Balance Exceeding Fourteen Days Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242049, P033A242049, P063P241644, P063Q241644 and P268K251644. Criteria. Under the Uniform Guidance, when Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Condition. During our testing, we identified one instance in which a student’s credit balance remained outstanding beyond the required 14‑day timeframe. Cause. This delay resulted from a voided Pell Grant refund that wasn't reissued until seventeen days after the credit balance was created. Effect. As a result of this condition, the College was not in compliance with the Uniform Guidance requirements governing the timely disbursement of student credit balances. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Recommendation. We recommend the College implement procedures to ensure all voided refunds are reviewed and resolved within the fourteen day period to ensure there are no credit balances that are unaddressed. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Cash Management - Excess Cash on Hand Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Management). Programs. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.033; Award Numbers P033A242049. Criteria. Under Uniform Guidance §200.305(b), payment methods must minimize the time elapsing between the transfer of Federal funds and the disbursement by the non‑Federal entity; advances must be limited to the minimum amounts needed and timed to actual, immediate cash requirements. For Title IV programs, excess cash is any amount of Title IV funds (other than Perkins) not disbursed by the end of the third business day after receipt or redeposit. An institution may hold a limited tolerance amount for up to seven days; any excess over the tolerance or held beyond seven days must be returned immediately. Title IV draws under the advance payment method may not exceed the amount needed immediately for disbursements the institution has made or will make to eligible students and must be disbursed within three business days of receipt. Condition. During our testing of cash management for campus-based aid, we noted one instance out of six drawdowns tested, that the College drew down Federal Work Study funds that were not needed for immediate disbursement, and was not returned timely. Cause. This delay resulted from management not having effective monitoring controls to (1) ensure Title IV draw requests were limited to immediate cash needs and (2) timely identify and return excess cash within the regulatory timeframes. Effect. As a result of this condition, the College was not in compliance with the Uniform Guidance cash management principles. Questioned Costs. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Although excess cash was maintained, all funds were ultimately either disbursed to eligible students or returned; therefore, no unallowable charges were identified to student accounts. Recommendation. We recommend the College strengthen its cash management controls to ensure Title IV drawdowns are limited to immediate disbursement needs, reconciled promptly, and any excess cash is identified and returned within required regulatory timeframes. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.