Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriate federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In cases where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Unclaimed Title IV FSA funds must not escheat to the state, revert to the College, or be transferred to any other third party. Condition: The College does not have a control in place to specifically monitor outstanding Title IV federal funded checks issued to students. This absence of oversight prevents the College from ensuring that these funds are returned within 240 days of check issuance. Questioned Costs: N/A. Context: During our testing, it was noted the College did not have a control in place to ensure the return of outstanding Title IV federally funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. Cause: The College did not have a control in place to ensure outstanding Title IV checks over 240 days are sent back to the Department of Education. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over outstanding checks and refunds of disbursements to students. Repeat Finding: Yes, 2024-003. Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must accurately report the enrollment status of all students regardless of whether they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reporting for both the Campus-Level and the Program-Level, as well as the program begin date. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Additionally, the College did not have a control process in place to ensure timely and accurate reporting. Questioned Costs: None. Context: In our sample of 60 students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 7 students had campus enrollment status reported incorrectly, 15 students had an enrollment effective date that did not match NSLDS, 60 students were reported past the 60-day reporting timeframe, 60 students were not certified every 60 days, 5 students where NSLDS Program enrollment effective date did not match the institutions records, 4 students where the students NSLDS Program enrollment status did not match the institutions records. Additionally, there was no observable review process to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify student’s status in NSLDS matched the institution’s records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes. 2024-002. Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not review the work or internal control reports of its third-party servicer who performs its monthly reconciliations for Title IV funds. Questioned Costs: N/A. Context: The College uses a third-party to perform its monthly reconciliations. The College did not review internal controls reports, such as SOC1 reports or perform other documented reviews of the third-party servicers work. Cause: The College did not have a control in place to review the controls and accuracy of the thirdparty servicers work. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over the direct loan, Pell, FSEOG, and FWS reconciliations. Repeat Finding: Yes, 2024-004. Recommendation: We recommend the College review internal control reports and implement review controls for work performed by third-party servicers. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: 34 CFR 668.22(a)(1) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment that the recipient began attendance in, the institution must determine the amount of Title IV assistance that the student earned in accordance with 34 CFR 668.22(e) which states that the calculation to determine this is equal to the percentage of the period of enrollment that the student completed as of the withdrawal date if this date occurs before completion of 60% of the period of enrollment. The amount unearned by the student is the complement of this percentage and is required to be returned as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as described in 34 CFR 668.22(j)(1). The withdrawal date is the date by which the student began the withdrawal process or provided official notification to the institution of intent to withdraw. If the student ceased attendance without providing notification to the institution the midpoint of the period of enrollment should be used. If the student’s ceasing attendance is due to illness, accident, or other circumstance beyond the students control the withdrawal date is date the institution becomes aware of these circumstances, as described in 668.22(c). Further (j)(2) states an institution not required to take attendance must determine the withdraw date for students who withdraw without providing notification to the institution no later than 30 days after the end of the earlier of the period of enrollment, academic year in which withdrawal occurred, or education program for which the student withdrew. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain effective internal controls designed to reasonably ensure compliance with federal laws, regulations, and program requirements related to these awards. Condition: The College did not accurately calculate Return of Title IV (R2T4) calculations. The College also did not maintain documentation of the internal controls to ensure the R2T4 process complied with federal regulations and guidelines. Questioned Costs: $5,458. Context: During our testing, it was noted out of our sample of 15, 2 students R2T4 calculation was not performed or not mechanically performed correctly. Additionally, the College does not have a formal review process in place to ensure compliance with federal laws, regulations, and program compliance requirements. Cause: The College does not have proper procedures in place to ensure R2T4 calculations are performed accurately and did not maintain documentation of the controls in place to ensure compliance with federal laws, regulation and program compliance requirements over R2T4. Effect: Failure to properly calculate R2T4 could result in the student returning an incorrect amount of aid. Further the lack of evidence of an internal control in place to ensure compliance with federal requirements could result in errors going undetected by the College. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. We also recommend the College maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance; Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 682.604) states a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program that the home institution approves for credit, written counseling materials may be provided by mail within 30 days after the student borrower completes the program. If a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Additionally, uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not send exit counseling notifications to students who graduated or withdrew during the fiscal year. Questioned Costs: None Context: During our eligibility testing, it was noted 6 of 6 students who were in our eligibility sample and either graduated or withdrew did not receive exit counseling notifications. Cause: The College did have a process within its system to send out exit counseling notifications, but it was not set up properly and students were not being notified of exit counseling requirements. The College did not have proper controls in place ensure exit counseling notifications were being sent out. Effect: The College is not in compliance with Department of Education requirements over exit counseling. Repeat Finding: No. Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdraw students throughout the year. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards must establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, regulations, and the terms and conditions of the award. Condition: The College did not properly identify students on satisfactory academic progress (SAP) suspension, resulting in disbursement of aid to ineligible students. Questioned Costs: $5,530 Context: During our testing of 60 students, we identified 4 students who were not meeting Satisfactory Academic Progress (SAP) requirements and were not placed on SAP suspension and received aid they were ineligible for. Cause: The college does not have a proper process to ensure students not meeting SAP requirements are not disbursed aid. Effect: Ineligible students received Title IV funds. Repeat Finding: 2024-006. Recommendation: We recommend that the College review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institutions SAP policy. Views of responsible officials: There is no disagreement with the finding.