Audit 5035

Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.

Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.

Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.

Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.