Audit 395523

FY End
2025-06-30
Total Expended
$21.96M
Findings
16
Programs
11
Year: 2025 Accepted: 2026-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1191660 2025-001 Material Weakness Yes N
1191661 2025-001 Material Weakness Yes N
1191662 2025-001 Material Weakness Yes N
1191663 2025-001 Material Weakness Yes N
1191664 2025-003 Material Weakness Yes L
1191665 2025-003 Material Weakness Yes L
1191666 2025-004 Material Weakness Yes N
1191667 2025-004 Material Weakness Yes N
1191668 2025-001 Material Weakness Yes N
1191669 2025-001 Material Weakness Yes N
1191670 2025-002 Material Weakness Yes N
1191671 2025-002 Material Weakness Yes N
1191672 2025-003 Material Weakness Yes L
1191673 2025-003 Material Weakness Yes L
1191674 2025-004 Material Weakness Yes N
1191675 2025-004 Material Weakness Yes N

Contacts

Name Title Type
T41BJJ3F9JZ9 Brian Lueth Auditee
2694884256 Kenley Penner Auditor
No contacts on file

Notes to SEFA

As allowable, and in accordance with federal regulations issued by the U.S. Department of Education, Kalamazoo Valley Community College transferred $55,000 of Federal Work Study (FWS) funds (84.033) to the Federal Supplemental Education Opportunity Grant (SEOG) funds (84.007) during the year ended June 30, 2025. The College carried forward and expended $26,533 and $20,000 of SEOG funds and FWS funds from the year ended June 30, 2024 to the year ended June 30, 2025. The College carried forward $27,700 of SEOG funds and $22,000 of FWS funds from the year ended June 30, 2025 to the year ending June 30, 2026.

Finding Details

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loans Program (ALN 84.268), Federal Supplemental Educational Opportunity Grant Program (ALN 84.007), and Federal Pell Grant Program (ALN 84.063) Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2024-002 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.220)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. Condition - Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Questioned Costs - N/A If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College did not review students who unofficially withdrew from the College during the summer 2024 semester. Out of our sample of 60 students who withdrew from the College during the fiscal year, 3 students did not have a return of Title IV funds calculation performed timely because of the lack of controls identified in the prior year requiring the College to amend previous returns. In total, the College amended 37 returns from the fall and summer 2024 semester. In addition, 1 student in the 2025 spring semester was not completed timely. Cause and Effect - The College experienced turnover in the financial aid department and, throughout the transition, historical procedures and controls were not followed. As a result, the controls to properly identify, calculate, and return Title IV funds for withdrawals were not operating effectively. Recommendation - The College should implement procedures and controls to review all the students who may need calculations completed and to verify that the information used in the Title IV calculations is accurate. Views of Responsible Officials and Planned Corrective Actions - The College will work with its Director of Financial Aid to ensure the semester end procedures include stepsto identify those students who unofficially withdrew. Once the students are identified,individuals with appropriate skills and knowledge will be able to determine if a return of Title IV calculation is necessary and appropriately return any funds, as necessary.
Assistance Listing Number, Federal Agency, and Program Name - 84.268, U.S. Department of Education, Student Financial Assistance Program - Federal Direct Student Loan Program Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - Yes - 2024-001 Criteria - Before a direct disbursement loan disbursement, the institution must notify a student of the amount of funds that the student or their parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include direct loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. After the direct loan disbursement, the institution must provide timely notification to the student of the (1) date and amount of the disbursement, (2) student/parent’s right to cancel, and (3) procedure and time by which the student or parent must notify the institution that he or she wishes to cancel (34 CFR 668.165). Condition - The College did not provide notifications to certain students related to direct loan disbursements. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - There were 2 students in a sample of 40 students receiving direct loans who did not receive a notification. Cause and Effect - A control was lacking to ensure the notifications were sent to all students receiving direct loans. Recommendation - We recommend a control be implemented to ensure notifications are sent to all students receiving direct loans. Views of Responsible Officials and Corrective Action Plan - The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the financial aid department to review and then send the appropriate notification. The department procedures will be updated to reflect these changes in process.
Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loans Program (ALN 84.268) and Federal Pell Grant Program (ALN 84.063) Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - Yes - 2024-003 Criteria - Institutions submit direct loan and Pell Grant origination records and disbursement records to the Common Origination and Disbursement (COD) system. (34 CFR 690.83) Condition - The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - None Identification of How Questioned Costs Were Computed - None Context - The College did not have appropriate controls in place due to turnover in 2024 over preparing the reconciliation from the College’s records to the COD system. In 2025, the reconciliation was performed monthly; however, they did not have the appropriate segregation of duties over the review of the reconciliation. Cause and Effect - The College experienced turnover in the financial aid department and, throughout the transition, historical procedures and controls were not followed. As a result, the control was not operating effectively to review reconciliations between Banner and COD. Recommendation - The College should implement appropriate review controls over the reconciliation of the amount of Pell Grants and direct loans reported to COD to ensure it agrees to what has been disbursed to students. Views of Responsible Officials and Planned Corrective Actions - The College will modify its process and update its documented procedures to include an appropriate review of the reconciliation by an individual separate from the process of preparing the reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - 84.268 U.S. Department of Education, Federal Direct Student Loans and 84.063 Federal Pell Grant Program Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition - Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Questioned Costs - None If Questioned Costs are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not be Reported - N/A Identification of How Questioned Costs Were Computed - None Context - The College's process for submitting the enrollment status change includes using the National Student Clearing House, a third party, which ultimately submits the status changes to NSLDS on behalf of the College. The submission the sample selections were submitted to the National Student Clearing house did reflect the appropriate status and effective date; however the date of the status change was not accurately transmitted by the National Student Clearing House to NSLDS based on the information provided by the College. Cause and Effect - The College did not have formal procedures to verify that the National Student Clearing House has accurately reported the data provided by the College to NSLDS, resulting in inappropriate enrollment status reported to NSLDS. Recommendation - The College should consider implementing a process to review all submissions to NSLDS to ensure the required reporting elements are submitted by the use of the third party. Views of Responsible Officials and Planned Corrective Actions - The College will modify its process and update its documented procedures to include periodically running an Enrollment Reporting Graduated/Withdrawn Report from NLSDS and review for accuracy and make timely corrections, if necessary.