2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-004 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Reporting ? Common Origination and Disbursement System (COD) Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0039 ? Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition - During our testing , we noted 42 instances out of 182 disbursement transactions tested where the disbursement date per the College?s records and the processing date at COD was outside the mandatory 15-day reporting window. In addition, we noted 52 instances out of 182 disbursement transactions tested where the disbursement date per the student?s record and the disbursement date per COD did not agree. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. Effect - The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 182 individual disbursements collectively were selected for testing. Repeat Finding ? Yes, prior year finding 2021-004 Recommendation - The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-005 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Reporting under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition - During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting was accurate. Effect - The College is not in compliance with the reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling ? Two student quarterly reports, three institutional quarterly reports, and the annual report required under HEERF and due within fiscal year 2022 were tested. Repeat Finding ? Yes, prior year finding 2021-005 Recommendation ? The reporting process was greatly improved over the prior year. The College should continue to ensure the process to review, update, and verify reporting under HEERF is done accurately is occurring. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.