Audit 46355

FY End
2022-06-30
Total Expended
$6.28M
Findings
34
Programs
8
Organization: Pillar College and Subsidiaries (NJ)
Year: 2022 Accepted: 2023-08-13
Auditor: Capincrouse LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
42229 2022-002 Material Weakness - N
42230 2022-003 Material Weakness Yes N
42231 2022-004 Significant Deficiency - E
42232 2022-005 Significant Deficiency - E
42233 2022-002 Material Weakness - N
42234 2022-003 Material Weakness Yes N
42235 2022-004 Significant Deficiency - E
42236 2022-006 - - E
42237 2022-003 Material Weakness Yes N
49674 2022-004 Significant Deficiency - E
49675 2022-003 Material Weakness Yes N
49676 2022-004 Significant Deficiency - E
49677 2022-004 Significant Deficiency - E
49678 2022-007 - - I
49679 2022-008 - - L
49680 2022-007 - - I
49681 2022-008 - - L
618671 2022-002 Material Weakness - N
618672 2022-003 Material Weakness Yes N
618673 2022-004 Significant Deficiency - E
618674 2022-005 Significant Deficiency - E
618675 2022-002 Material Weakness - N
618676 2022-003 Material Weakness Yes N
618677 2022-004 Significant Deficiency - E
618678 2022-006 - - E
618679 2022-003 Material Weakness Yes N
626116 2022-004 Significant Deficiency - E
626117 2022-003 Material Weakness Yes N
626118 2022-004 Significant Deficiency - E
626119 2022-004 Significant Deficiency - E
626120 2022-007 - - I
626121 2022-008 - - L
626122 2022-007 - - I
626123 2022-008 - - L

Contacts

Name Title Type
NMWBFNX1UZQ3 Giselle Llerena Auditee
9738035000 Brent Smith, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO CONSOLIDATED FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards and state financial assistance (the schedule) includes the federal and state grant activity of Pillar College and Subsidiaries (College) under programs of the federal and New Jersey state governments for the year ending June 30, 2022. The information in the schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and New Jersey OMB Circular 15-08, Single Audit Policy for Recipients of Federal Grants, State Grants and State Aid (Circular 15-08). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. See table in SEFA Note 3.
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUAR Accounting Policies: The accompanying schedule of expenditures of federal awards and state financial assistance (the schedule) includes the federal and state grant activity of Pillar College and Subsidiaries (College) under programs of the federal and New Jersey state governments for the year ending June 30, 2022. The information in the schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and New Jersey OMB Circular 15-08, Single Audit Policy for Recipients of Federal Grants, State Grants and State Aid (Circular 15-08). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The College did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans or loan guarantees.
Title: COVID-19 TITLE IV TRANSFERS AND EXPENSES Accounting Policies: The accompanying schedule of expenditures of federal awards and state financial assistance (the schedule) includes the federal and state grant activity of Pillar College and Subsidiaries (College) under programs of the federal and New Jersey state governments for the year ending June 30, 2022. The information in the schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and New Jersey OMB Circular 15-08, Single Audit Policy for Recipients of Federal Grants, State Grants and State Aid (Circular 15-08). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and Circular 15-08, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. As allowed by the CARES Act sections 3503 and 3504 in response to COVID-19, the College used $12,854 of Federal Supplemental Educational Opportunity Grants Program (FSEOG) to award COVID-19 emergency FSEOG financial aid grants to students.

Finding Details

Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) accurately. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 19 students had been reported to NSLDS correctly as enrolled at the program level but reported as withdrawn at the campus level. Cause: It was discovered in March 2023 that the student information system was incorrectly processing the NSLDS Enrollment reporting. The College has a file of all students that need to be updated and corrected, which will be processed this summer. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the College spot check students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: Students were not initially awarded subsidized aid based on need. Criteria: 34 CFR 668.42 & 34 CFR 685.301 Questioned Costs: $0 Context: Out of 60 students, 3 students were not awarded aid appropriately based on need analysis. 2 students received unsubsidized loans when they were eligible for subsidized loan totaling $1,564 under awarded. 1 student was awarded $3,765 subsidized loans in excess of need due to institutional scholarships excluded from estimated financial assistance. Cause: No secondary review of awarding. Effect: Students not awarded need based federal aid according to eligibility. Incorrect allocation of subsidized versus unsubsidized loans affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the College or their third-party administrator set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) accurately. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 19 students had been reported to NSLDS correctly as enrolled at the program level but reported as withdrawn at the campus level. Cause: It was discovered in March 2023 that the student information system was incorrectly processing the NSLDS Enrollment reporting. The College has a file of all students that need to be updated and corrected, which will be processed this summer. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the College spot check students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: 2 students out of 41 tested were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $612 Context: 1 student was disbursed Pell based on full time enrollment but the student only attended halftime resulting in a $612 Pell over awarded for a term. 1 student was only disbursed for halftime enrollment but attended fulltime resulting in a $1,624 Pell under awarded for a term. Cause: Changes in enrollment status not caught Effect: Students not disbursed Pell awards for which they were eligible. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that a review of Pell awards based on enrollment status be completed after each term to ensure that enrollment changes are captured and Pell adjusted accordingly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) accurately. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 19 students had been reported to NSLDS correctly as enrolled at the program level but reported as withdrawn at the campus level. Cause: It was discovered in March 2023 that the student information system was incorrectly processing the NSLDS Enrollment reporting. The College has a file of all students that need to be updated and corrected, which will be processed this summer. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the College spot check students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: Students were not initially awarded subsidized aid based on need. Criteria: 34 CFR 668.42 & 34 CFR 685.301 Questioned Costs: $0 Context: Out of 60 students, 3 students were not awarded aid appropriately based on need analysis. 2 students received unsubsidized loans when they were eligible for subsidized loan totaling $1,564 under awarded. 1 student was awarded $3,765 subsidized loans in excess of need due to institutional scholarships excluded from estimated financial assistance. Cause: No secondary review of awarding. Effect: Students not awarded need based federal aid according to eligibility. Incorrect allocation of subsidized versus unsubsidized loans affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the College or their third-party administrator set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) accurately. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 19 students had been reported to NSLDS correctly as enrolled at the program level but reported as withdrawn at the campus level. Cause: It was discovered in March 2023 that the student information system was incorrectly processing the NSLDS Enrollment reporting. The College has a file of all students that need to be updated and corrected, which will be processed this summer. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the College spot check students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: 2 students out of 41 tested were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $612 Context: 1 student was disbursed Pell based on full time enrollment but the student only attended halftime resulting in a $612 Pell over awarded for a term. 1 student was only disbursed for halftime enrollment but attended fulltime resulting in a $1,624 Pell under awarded for a term. Cause: Changes in enrollment status not caught Effect: Students not disbursed Pell awards for which they were eligible. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that a review of Pell awards based on enrollment status be completed after each term to ensure that enrollment changes are captured and Pell adjusted accordingly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.