Audit 405683

FY End
2025-09-30
Total Expended
$9.98M
Findings
5
Programs
18
Organization: College of the Muscogee Nation (OK)
Year: 2025 Accepted: 2026-06-30
Auditor: HOGANTAYLOR LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
1221345 2025-001 Material Weakness Yes N
1221346 2025-002 Material Weakness Yes N
1221347 2025-003 Material Weakness Yes L
1221348 2025-004 Material Weakness Yes N
1221349 2025-005 Material Weakness Yes N

Contacts

Name Title Type
RBHCY8PPJVS9 Linette Factor Auditee
9185492803 David Stiles Auditor
No contacts on file

Notes to SEFA

The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal awards activity of College of The Muscogee Nation (the College) under programs of the federal government for the year ended September 30, 2025. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the financial position, changes in net position, or cashflows of the College.
The College has elected not to use the ten percent de minimis indirect cost rate allowed under the Uniform Guidance.
Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the applicable cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or limited as to reimbursement. Pass-through entity identifying numbers are presented where available.
The College provided no federal award to subrecipients.

Finding Details

Item 2025-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In accordance with the Uniform Grant Guidance for student financial assistance programs and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, institutions are required to report enrollment information under the Pell grant via the NSLDS. Institutions are responsible for accurately and timely reporting the OPEID number, enrollment effective date, enrollment status and certification date. Out of a sample of six students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. In addition, four students did not have the correct enrollment effective date submitted to NSLDS. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures did not adequately verify the information was submitted to the NSLDS timely and accurately. Finding is a repeat of finding 2024-001 in the immediately prior audit. Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in changes to future awards to the student. We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Item 2025-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed within the maximum time allowed for two students that required a return of funds. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the Title IV worksheet was completed timely. Finding is a repeat of finding 2024-002 in the immediately prior audit. Not timely preparing a calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed timely to ensure the processing of returns is completed within the required time frame. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Item 2025-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Out of a sample of 14 students who received Federal Pell Grants during the audit period, six students did not have the correct disbursement date submitted to the COD system, resulting in a difference of four days between the dates submitted to the COD system and the actual dates the funds were disbursed. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Finding is a repeat of finding 2024-003 in the immediately prior audit. Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Item 2025-004 – Special Tests: Title IV Eligibility Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Title 34 CFR 668.34(a)(5)(ii) establishes the maximum timeframe requirement for Title IV Eligibility. For an undergraduate program measured in credit hours, the maximum timeframe to be eligible is a period no longer than 150 percent of the published length of the educational program, as measured in credit hours, or expressed in calendar time. Out of a sample of 14 students, one student was not eligible to receive aid as they exceeded the 150 percent rule but received $616 of Pell during the period. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Procedures were not in place to verify the student had not exceeded the allowable credit hours attempted. Not a repeat finding. Inaccurate disbursement of the Title IV funds to be given to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions. We recommend that the Financial Aid Coordinator institute procedures that would detect whether a student has reached the maximum number of courses to remain eligible for aid. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Item 2025-005 – Special Tests: Disbursements to or on Behalf of Students Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Title 34 CFR Section 690.62 states the amount of a student's Federal Pell Grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Out of a sample of 14 students, one student Federal Pell Grant calculation was calculated incorrectly resulting in an under award to the student. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. The College did not implement the new Federal Pell Grant calculations to include enrollment intensity. Not a repeat finding. Inaccurate calculation of the Title IV funds to be given to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute procedures that would ensure that Pell calculations are performed accurately and policy changes from the Department of Education are reviewed. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.