Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loans Program (ALN 84.268); 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 - No Criteria - The College has 60 days from the date of the College determines an enrollment status change to report to the National Student Loan Data System (NSLDS). 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 - The College did not update the student enrollment information for any of the students graduating in Fall of 2024. 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 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 of graduated students was returned to the College with a notice of error and was not transmitted to NSLDS. The College never resubmitted the graduates to NSLDS for proper enrollment status. 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 Corrective Action Plan - Lake Michigan College understands the significance of accurately reporting student enrollment statuses and will implement enhanced oversight controls. This includes the creation of a log that now documents file “receipts” from the National Student Clearinghouse. These report receipts are then reconciled to file submissions to ensure all files were received. Additionally, we have implemented a more overarching review that ensures all files are adequately processed by the National Clearinghouse.
Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster - Federal Direct Student Loans Program (ALN 84.268), Federal Work Study Program (ALN 84.033), 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 - Significant deficiency Repeat Finding - Yes 2024-001 Criteria - If an institution enters into a Tier One arrangement with a third party servicer, as defined in CFR 668.164(e)(1), the institution must provide to the secretary an up to date URL for the contract and contract data, as described in paragraph (e)(2)(vii) of this section for publication in a centralized database accessible to the public. Condition - Colleges are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. The school did not provide a URL for the contracts or cost information of its Tier One provider to the Department of Education for publication in the Cash Management Contracts Database. 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 did not provide a URL for the contracts or cost information of its Tier One provider to the Department of Education for publication in the Cash Management Contracts Database. Cause and Effect - A control was lacking to ensure the URL for the contract of its Tier One Provider was published in the Cash Management Contracts Database. Recommendation - We recommend a control be implemented to ensure new contracts or cost information are published in the Cash Management Contracts Database. Views of Responsible Officials and Planned Corrective Actions - The URL associated with Lake Michigan’s required disclosure has now been provided to the secretary via the associated Department of Education’s instructions.
Assistance Listing, 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 - Significant deficiency 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 - The College did not perform an accurate calculation to determine the amount of funds to return of Title IV funds for 2 students. Questioned Costs - $1,247 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 - Questioned costs of $1,247 resulted from the College calculating a return of Title IV funds of $1,195 and the actual amount of funds returned was $2,442. Context - Of the 40 students tested, there was 2 students for whom there was error in the calculation that resulted in the improper amount being returned to the Department of Education. Cause and Effect - A control was not operating appropriately to ensure amounts calculated to be refunded agree to the actual amounts refunded to the Department of Education. Recommendation - The College should implement procedures and controls to review the calculations to ensure compliance with federal regulations. Views of Responsible Officials and Planned Corrective Actions - Accuracy in performing the required Return to Title IV Funds function is of significant importance to Lake Michigan College. Currently, a second individual performs an independent review of a sample of calculations. Although we find these two scenarios to be isolated in nature, we will increase our quality control sample review. We are also investigating how we might automate more of the process in order to help reduce any manual error.
Assistance Listing, Federal Agency, and Program Name - 21.027 COVID 19 Coronavirus State and Local Fiscal Recovery Funds, Academic Catch up Program, ADN to BSN Completion Grant Program, Reconnect Age Expansion Grant Program Federal Award Identification Number and Year - SLFRP0127 and GG 186 240000003828 Pass through Entity - Michigan Community College Association and Michigan Department of Lifelong Education, Advancement, and Potential Finding Type - Material weakness Repeat Finding - No Criteria - When awarding contracts over $25,000, the College is required to review and maintain evidence that the vendors are neither suspended or debarred. Condition - The College did not perform suspension or debarment for vendors subject to the College's sole source justification procurement process. 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 - Of the two purchases that were tested for suspension and debarment, there was not adequate documentation for the one vendor that was subject to the sole source procurement process to determine the College verified the vendor was not suspended or debarred. Cause and Effect - The College had not established a control to ensure that contracts and vendors subject to their sole source justification procurement process were reviewed for supsenion and debarment. Recommendation - The College should implement a process to review certificates or other support to verify that vendors are not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions - The College will implement procedures to ensure suspension and debarment verification is consistently performed for vendors subject to sole source justification. Specifically, SAM.gov verification will be conducted and documented prior to approving a sole source request, during contract review, and before issuing a purchase order. A Procurement Checklist will be implemented to ensure this verification step is completed as part of the procurement process. Additionally, evidence of the SAM.gov search, such as a screenshot or saved record, will be retained in the procurement file to support compliance.