Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: For the (a)(1) Student Aid Portion (Assistance Listing 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. ED?s (Eligibility to Receive Emergency Financial Aid Grants to Students under the Higher Education Emergency Relief Programs, May 14, 2021) on student eligibility for HEERF states that all students who are or were enrolled in an institution of higher education on or after the date of the declaration of the national emergency due to the coronavirus (March 13, 2020) are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. As it relates to expenditures under the (a)(1) Student Aid Portion, auditors should determine (1) the college or university had a documented plan to distribute funds to students, (2) that the college or university did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, and (3) the college or university expended the entirety of the Student Aid Portion grant on financial aid grants to students and that the college or university did not reimburse itself for any costs or expenses previously issued to students. Condition: During our testing, we noted Clarkson College did not follow their documented distribution plan that was uploaded to their website. Questioned Costs: None Context: The documented distribution plan was for students with an EFC $0-25,000 to receive a disbursement of $1,000 while students with EFC greater than $25,000 received a disbursement of $500. The actual disbursement plan was for students who were Pell eligible during 2022 to receive a $1,000 HEERF disbursement while Non-Pell eligible students to receive a $500 disbursement. Cause: The colleges did not comply with (ED) regulations for allowable costs. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the colleges reevaluate their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: During our testing, we noted that for one of the four disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Questioned Costs: None Context: The College did not have appropriate documentation that met the federal procurement requirements. Cause: The College was unable to locate the support for the procurement procedures followed for this specific disbursement. Effect: The College did not have appropriate documentation that met the federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the College review its procurement policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: During our testing, we noted that for one of the four disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Questioned Costs: None Context: The College did not have appropriate documentation that met the federal procurement requirements. Cause: The College was unable to locate the support for the procurement procedures followed for this specific disbursement. Effect: The College did not have appropriate documentation that met the federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the College review its procurement policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: During our testing, we noted that for one of the four disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Questioned Costs: None Context: The College did not have appropriate documentation that met the federal procurement requirements. Cause: The College was unable to locate the support for the procurement procedures followed for this specific disbursement. Effect: The College did not have appropriate documentation that met the federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the College review its procurement policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted one disbursement per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 1 of the 10 individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: $3,911 Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College's used the incorrect withdrawal date thus students % of days attended was miscalculated. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Financial Aid Administrator and Controller was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the Financial Aid Administrator and Controller had a change in position and it was not updated within 10 days. Cause: During 2021, the Financial Aid Administrator and Controller both departed the College. A replacement was not immediately named and was not report to the Department of Education until the permanent replacements began employment several months later. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 6 of the 40 students enrollment date per institution's record did not match the date reported to NSLDS. Furthermore, 5 out of the 40 students had an incorrect effective enrollment date that was reported at the program level. Lastly, 1 of the 40 days was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: During our testing, it was noted the College did not have proper procedures in place to verify the reports sent to NSLDS are including accurate information and being updated timely. Cause: The College did not timely or properly report student status changes to NSLDS. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the College establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS for both the Campus-Level and the Program-Level. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted the College did not have a formal review of their monthly reconciliations related to Direct Loans, Pell, SEOG, FWS nor did they have a review prior to their G5 drawdowns. Likewise, the College did not have a formal review of their award packaging during the 2021-22 academic year. Lastly, the College did not have a formal review of their return of Title IV fund calculations. Questioned Costs: None Context: The College did not have proper internal controls in place during the 2021-22 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The College's processes and controls were not formally documented during the year as they had significant turnover in the financial aid department. Effect: The College is not following the compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No Recommendation: We recommend the College review its procedures to ensure the students' cost of attendance is correctly reported to ensure proper awarding. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: For the (a)(1) Student Aid Portion (Assistance Listing 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. ED?s (Eligibility to Receive Emergency Financial Aid Grants to Students under the Higher Education Emergency Relief Programs, May 14, 2021) on student eligibility for HEERF states that all students who are or were enrolled in an institution of higher education on or after the date of the declaration of the national emergency due to the coronavirus (March 13, 2020) are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. As it relates to expenditures under the (a)(1) Student Aid Portion, auditors should determine (1) the college or university had a documented plan to distribute funds to students, (2) that the college or university did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, and (3) the college or university expended the entirety of the Student Aid Portion grant on financial aid grants to students and that the college or university did not reimburse itself for any costs or expenses previously issued to students. Condition: During our testing, we noted Clarkson College did not follow their documented distribution plan that was uploaded to their website. Questioned Costs: None Context: The documented distribution plan was for students with an EFC $0-25,000 to receive a disbursement of $1,000 while students with EFC greater than $25,000 received a disbursement of $500. The actual disbursement plan was for students who were Pell eligible during 2022 to receive a $1,000 HEERF disbursement while Non-Pell eligible students to receive a $500 disbursement. Cause: The colleges did not comply with (ED) regulations for allowable costs. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the colleges reevaluate their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: During our testing, we noted that for one of the four disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Questioned Costs: None Context: The College did not have appropriate documentation that met the federal procurement requirements. Cause: The College was unable to locate the support for the procurement procedures followed for this specific disbursement. Effect: The College did not have appropriate documentation that met the federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the College review its procurement policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: During our testing, we noted that for one of the four disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Questioned Costs: None Context: The College did not have appropriate documentation that met the federal procurement requirements. Cause: The College was unable to locate the support for the procurement procedures followed for this specific disbursement. Effect: The College did not have appropriate documentation that met the federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the College review its procurement policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. Condition: During our testing, we noted that for one of the four disbursements tested for procurement the College was unable to provide support that it obtained a formal bid or market intelligence analysis before the purchase was made. Questioned Costs: None Context: The College did not have appropriate documentation that met the federal procurement requirements. Cause: The College was unable to locate the support for the procurement procedures followed for this specific disbursement. Effect: The College did not have appropriate documentation that met the federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the College review its procurement policy to ensure a process is in place to follow its policy. Documentation should be retained to support that the policy was followed. Views of responsible officials: There is no disagreement with the audit finding.