Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to National Student Loan Data System (NSLDS) NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. 34 CFR 685.309(b), states that Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Condition: The College did not comply with NSLDS enrollment reporting requirements. Questioned costs: None Context: This condition occurred as follows out of 60 students selected for testing: ? For 3 students, the enrollment status was not reported correctly ? For 4 students, the enrollment status effective date could not be verified ? For 30 students, the change in enrollment status was not reported timely ? For 8 students, we could not verify that the CIP code per NSLDS agreed to the institution?s records ? For 60 students, the incorrect program length was reported in NSLDS ? For 1 student, the program begin date was not reported in NSLDS. Cause: Due to an unexpected loss of staff and institutional knowledge in the Registrar?s Office, some of the processes for updating a student?s record, whether for a change of program or to a withdrawal status, were learned via documentation available without any resident expertise. Some errors were made in the learning process. However, with the help of an outside consultant, correct procedures have since been implemented. For the 60 students whose program length was incorrectly reported; this is due to the fact that the institution reported on the National Student Clearinghouse?s website that the bachelor?s degree takes 48 months to complete. Our bachelor?s degree is a four-year degree and should not have been reported in months. The Clearinghouse translated 48 months to the incorrect number of years. This is being corrected. Effect: The NSLDS system is not updated with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2021-002 Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to National Student Loan Data System (NSLDS) NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. 34 CFR 685.309(b), states that Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Condition: The College did not comply with NSLDS enrollment reporting requirements. Questioned costs: None Context: This condition occurred as follows out of 60 students selected for testing: ? For 3 students, the enrollment status was not reported correctly ? For 4 students, the enrollment status effective date could not be verified ? For 30 students, the change in enrollment status was not reported timely ? For 8 students, we could not verify that the CIP code per NSLDS agreed to the institution?s records ? For 60 students, the incorrect program length was reported in NSLDS ? For 1 student, the program begin date was not reported in NSLDS. Cause: Due to an unexpected loss of staff and institutional knowledge in the Registrar?s Office, some of the processes for updating a student?s record, whether for a change of program or to a withdrawal status, were learned via documentation available without any resident expertise. Some errors were made in the learning process. However, with the help of an outside consultant, correct procedures have since been implemented. For the 60 students whose program length was incorrectly reported; this is due to the fact that the institution reported on the National Student Clearinghouse?s website that the bachelor?s degree takes 48 months to complete. Our bachelor?s degree is a four-year degree and should not have been reported in months. The Clearinghouse translated 48 months to the incorrect number of years. This is being corrected. Effect: The NSLDS system is not updated with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2021-002 Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR section 200.320. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Per 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: Documentation was not maintained to support why vendors were selected using noncompetitive procurement. Furthermore, the documentation to support the vendor?s suspension debarment status was not provided. Questioned costs: None Context: For 5 of 7 procurement transactions greater than $10,000, no documentation was provided to justify noncompetitive procurement method used. 3 of the 7 vendors exceeded $25,000 in procurement and further were not reviewed to ensure the vendors were not suspended or disbarred. Cause: The College used vendors that have been historically used by the institution during non-pandemic periods of time to acquire needed supplies and materials for the suppression and monitoring of COVID where possible. Several purchases that were needed for these efforts were not available from the College?s normal vendors and those costs had to be acquired from new sources. Multiple sources were investigated, but with supply chain issues, the College was unable to always find multiple vendors that could meet the needs of the institution. With changes in staffing at the institution, the records related to the processes used and vendor?s investigated have not been retained. The vendor?s used have all subsequently been checked for suspension debarment status and none where found to have any issues. Effect: Vendors may be selected in a manner that is not consistent with Federal guidelines and Federal funds may be paid to parties that are ineligible to participate in a Federal program. Repeat Finding: No Recommendation: We recommend the College establish policies and procedures to properly identify procured transactions and maintain documentation to support performance of the procurement procedures. We also recommend the College evaluate its policies procedures to ensure that suspension and debarment requirements are being met prior to entering into transactions with vendors. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative. Condition: Quarterly student reports were incorrectly reported on a cumulative basis. Questioned costs: None Context: This condition occurred for 2 out of 4 quarterly student reports. Cause: Washington College made every attempt to keep up with guidance for posting quarterly reports to our webpage. While the reports were posted, they totals were cumulative instead of what was spent for that quarter. Effect: The College is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: No Recommendation: We recommend the College obtain an understanding of the reporting requirements established by the grant to ensure reports do not report on a cumulative basis. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to National Student Loan Data System (NSLDS) NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. 34 CFR 685.309(b), states that Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Condition: The College did not comply with NSLDS enrollment reporting requirements. Questioned costs: None Context: This condition occurred as follows out of 60 students selected for testing: ? For 3 students, the enrollment status was not reported correctly ? For 4 students, the enrollment status effective date could not be verified ? For 30 students, the change in enrollment status was not reported timely ? For 8 students, we could not verify that the CIP code per NSLDS agreed to the institution?s records ? For 60 students, the incorrect program length was reported in NSLDS ? For 1 student, the program begin date was not reported in NSLDS. Cause: Due to an unexpected loss of staff and institutional knowledge in the Registrar?s Office, some of the processes for updating a student?s record, whether for a change of program or to a withdrawal status, were learned via documentation available without any resident expertise. Some errors were made in the learning process. However, with the help of an outside consultant, correct procedures have since been implemented. For the 60 students whose program length was incorrectly reported; this is due to the fact that the institution reported on the National Student Clearinghouse?s website that the bachelor?s degree takes 48 months to complete. Our bachelor?s degree is a four-year degree and should not have been reported in months. The Clearinghouse translated 48 months to the incorrect number of years. This is being corrected. Effect: The NSLDS system is not updated with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2021-002 Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to National Student Loan Data System (NSLDS) NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. 34 CFR 685.309(b), states that Institutions must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The institution is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Condition: The College did not comply with NSLDS enrollment reporting requirements. Questioned costs: None Context: This condition occurred as follows out of 60 students selected for testing: ? For 3 students, the enrollment status was not reported correctly ? For 4 students, the enrollment status effective date could not be verified ? For 30 students, the change in enrollment status was not reported timely ? For 8 students, we could not verify that the CIP code per NSLDS agreed to the institution?s records ? For 60 students, the incorrect program length was reported in NSLDS ? For 1 student, the program begin date was not reported in NSLDS. Cause: Due to an unexpected loss of staff and institutional knowledge in the Registrar?s Office, some of the processes for updating a student?s record, whether for a change of program or to a withdrawal status, were learned via documentation available without any resident expertise. Some errors were made in the learning process. However, with the help of an outside consultant, correct procedures have since been implemented. For the 60 students whose program length was incorrectly reported; this is due to the fact that the institution reported on the National Student Clearinghouse?s website that the bachelor?s degree takes 48 months to complete. Our bachelor?s degree is a four-year degree and should not have been reported in months. The Clearinghouse translated 48 months to the incorrect number of years. This is being corrected. Effect: The NSLDS system is not updated with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2021-002 Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR section 200.320. Noncompetitive procurement can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Per 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Condition: Documentation was not maintained to support why vendors were selected using noncompetitive procurement. Furthermore, the documentation to support the vendor?s suspension debarment status was not provided. Questioned costs: None Context: For 5 of 7 procurement transactions greater than $10,000, no documentation was provided to justify noncompetitive procurement method used. 3 of the 7 vendors exceeded $25,000 in procurement and further were not reviewed to ensure the vendors were not suspended or disbarred. Cause: The College used vendors that have been historically used by the institution during non-pandemic periods of time to acquire needed supplies and materials for the suppression and monitoring of COVID where possible. Several purchases that were needed for these efforts were not available from the College?s normal vendors and those costs had to be acquired from new sources. Multiple sources were investigated, but with supply chain issues, the College was unable to always find multiple vendors that could meet the needs of the institution. With changes in staffing at the institution, the records related to the processes used and vendor?s investigated have not been retained. The vendor?s used have all subsequently been checked for suspension debarment status and none where found to have any issues. Effect: Vendors may be selected in a manner that is not consistent with Federal guidelines and Federal funds may be paid to parties that are ineligible to participate in a Federal program. Repeat Finding: No Recommendation: We recommend the College establish policies and procedures to properly identify procured transactions and maintain documentation to support performance of the procurement procedures. We also recommend the College evaluate its policies procedures to ensure that suspension and debarment requirements are being met prior to entering into transactions with vendors. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. According to the OPE Reporting and Data Collection website, quarterly reports should appear on separate documents by quarter and should not be cumulative. Condition: Quarterly student reports were incorrectly reported on a cumulative basis. Questioned costs: None Context: This condition occurred for 2 out of 4 quarterly student reports. Cause: Washington College made every attempt to keep up with guidance for posting quarterly reports to our webpage. While the reports were posted, they totals were cumulative instead of what was spent for that quarter. Effect: The College is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: No Recommendation: We recommend the College obtain an understanding of the reporting requirements established by the grant to ensure reports do not report on a cumulative basis. Views of responsible officials: There is no disagreement with the audit finding.