Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-004: Disbursements to or on Behalf of Students - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: An institution must pay credit balances to students no later than 14 days after the balance occurred if the balance occurred after the first day of class of that payment period, or 14 days after the first day of class if the balance occurred on or before the first day of class. When a valid waiver has been obtained, an institution must pay the remaining balance on loan funds by the end of the loan period and any remaining other Title IV program funds by the end of the last payment period in the award year for which the funds were awarded (34 CFR 668.164 and 668.165). Distributions to first time borrowers should be 30 days after the first day of classes (34 CFR 685.303). Condition and Context: For 13 of the 25 students selected for testing, a credit balance was late being paid back to the student, a waiver was not obtained, and the College is on the reimbursement payment method. For one of the 25 students selected for testing, disbursement was made to the first time student prior to 30 days after the first day of classes. Our sample was not statistically valid. Cause and Effect: The College experienced several personnel changes in the financial aid office and did not have proper controls in place to monitor these requirements. As a result, the College was holding funds that needed to be returned to the student and not strictly adhering to the rules for first time borrowers. Recommendation: We recommend the College develop sufficient, appropriate internal controls over the disbursement of Title IV funds to students in a timely manner when a credit balance is created on their account and adhere to disbursement rules to first time students. Management Response: Management agrees with this finding. The Office of Financial Aid will continue to run student disbursements on a daily basis. The Vice President of Finance, Operations, and Information Technology and the Director of Financial Operations will enforce policies and procedures to ensure the student refund process is performed and reviewed on a timely basis.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-009: Eligibility ? Significant Deficiency and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 Federal Award Year: June 30, 2022 Criterion: Title IV regulations (34 CFR 630.63) determines the method of calculating the Pell Award for a payment period. Condition and Context: For three of the twenty-five students selected for testing, the Pell Award calculation was not correctly performed, and the students did not receive an adequate amount of Pell Award for the period under audit. Our sample was not statistically valid. Cause and Effect: The College experienced several personnel changes in the financial aid office and did not have proper controls in place to monitor these requirements. As a result, the College did not perform adequate review and approval procedures over the calculation of the Pell Award. Recommendation: We recommend the College develop sufficient, appropriate internal controls over the calculation of the Pell Award for students. Management Response: Management agrees with this finding. The Vice President of Finance, Operations and IT and the Director of Financial Operations will enforce policies and procedures to ensure the Pell Award calculation are accurately performed.
Finding 2022-004: Disbursements to or on Behalf of Students - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: An institution must pay credit balances to students no later than 14 days after the balance occurred if the balance occurred after the first day of class of that payment period, or 14 days after the first day of class if the balance occurred on or before the first day of class. When a valid waiver has been obtained, an institution must pay the remaining balance on loan funds by the end of the loan period and any remaining other Title IV program funds by the end of the last payment period in the award year for which the funds were awarded (34 CFR 668.164 and 668.165). Distributions to first time borrowers should be 30 days after the first day of classes (34 CFR 685.303). Condition and Context: For 13 of the 25 students selected for testing, a credit balance was late being paid back to the student, a waiver was not obtained, and the College is on the reimbursement payment method. For one of the 25 students selected for testing, disbursement was made to the first time student prior to 30 days after the first day of classes. Our sample was not statistically valid. Cause and Effect: The College experienced several personnel changes in the financial aid office and did not have proper controls in place to monitor these requirements. As a result, the College was holding funds that needed to be returned to the student and not strictly adhering to the rules for first time borrowers. Recommendation: We recommend the College develop sufficient, appropriate internal controls over the disbursement of Title IV funds to students in a timely manner when a credit balance is created on their account and adhere to disbursement rules to first time students. Management Response: Management agrees with this finding. The Office of Financial Aid will continue to run student disbursements on a daily basis. The Vice President of Finance, Operations, and Information Technology and the Director of Financial Operations will enforce policies and procedures to ensure the student refund process is performed and reviewed on a timely basis.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-006: Direct Loan Reconciliation - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 685.300(b)(5) states that on a monthly basis the College must reconcile institutional records with direct loan fund records received from the Secretary and direct loan disbursement records submitted to and accepted by the Secretary. Condition and Context: Documentation that the required monthly School Account Statement (SAS) reconciliations were not completed for any of the three monthly tested for the year ended June 30, 2022. This sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the SAS reconciliations were performed and reviewed, and as a result, the College did not perform the required monthly reconciliations which could result in variances between the records of the College and the U.S. Department of Education, which could impact the student. Recommendation: The College should implement a process and related control to ensure that the SAS reconciliations are performed monthly and reviewed in a timely manner by the relevant person and to a sufficient level of detail. Management Response: Management agrees with the finding. The Director of Financial Aid will ensure the implementation of procedures and controls in 2023 to ensure monthly School Account Statements (SAS) are processed and reviewed in a timely manner.
Finding 2022-007: Late Student Status Change Reporting - Significant Deficiency and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criterion: Title IV regulations require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the Institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the Institution and who received a loan under Title IV of the Act has changed his or her permanent address. In addition, the Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of controls over applicable compliance requirements. Condition and Context: The change in status for one of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a roster file within 60 days. The sample was not statistically valid. Cause and Effect: The generation of enrollment reports changes is a manual process that, if not performed or reviewed to a sufficient level of detail, is subject to issues with the completeness and accuracy of information in the report. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment statuses, effective dates of enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: The College should develop a way to reliably generate a report that contains exactly the information required for student status changes. The College should review and revise its controls over compliance to ensure that student status changes are reported in a timely manner. Management Response: Management agrees with the finding. The Director of Financial Aid and Registrar will implement procedures and controls in 2023 to ensure student status changes are processed and reviewed in a timely manner.
Finding 2022-008: Improper HEERF Student and Institutional Aid Reporting - Significant Deficiency and Noncompliance Federal Program: COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund - Student and Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Criterion: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all Sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition and Context: There were no student quarterly reports posted to the College's website for the quarters ending September 30, 2021, December 31, 2021, and March 31, 2022 and the institutional quarterly reports were posted late for the quarters ending September 30, 2021, December 31, 2021 and March 31, 2022. Cause and Effect: The College did not have an adequate control to ensure that all of the student quarterly reports were posted to their website or the institutional reports were posted timely to their website, and as a result, the reports were not posted or posted timely, respectively. Recommendation: The College should implement a process and related control to ensure that HEERF reporting requirements are met in a timely manner. Management Response: The Director of Sponsored Programs will ensure the implementation of procedures and controls in 2023 to ensure timely submission of Education Stabilization Funds (ESF) and Higher Education Relief Funds (HEERF) student and institutional quarterly reports are submitted in a timely manner.
Finding 2022-008: Improper HEERF Student and Institutional Aid Reporting - Significant Deficiency and Noncompliance Federal Program: COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund - Student and Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Criterion: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all Sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition and Context: There were no student quarterly reports posted to the College's website for the quarters ending September 30, 2021, December 31, 2021, and March 31, 2022 and the institutional quarterly reports were posted late for the quarters ending September 30, 2021, December 31, 2021 and March 31, 2022. Cause and Effect: The College did not have an adequate control to ensure that all of the student quarterly reports were posted to their website or the institutional reports were posted timely to their website, and as a result, the reports were not posted or posted timely, respectively. Recommendation: The College should implement a process and related control to ensure that HEERF reporting requirements are met in a timely manner. Management Response: The Director of Sponsored Programs will ensure the implementation of procedures and controls in 2023 to ensure timely submission of Education Stabilization Funds (ESF) and Higher Education Relief Funds (HEERF) student and institutional quarterly reports are submitted in a timely manner.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-004: Disbursements to or on Behalf of Students - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: An institution must pay credit balances to students no later than 14 days after the balance occurred if the balance occurred after the first day of class of that payment period, or 14 days after the first day of class if the balance occurred on or before the first day of class. When a valid waiver has been obtained, an institution must pay the remaining balance on loan funds by the end of the loan period and any remaining other Title IV program funds by the end of the last payment period in the award year for which the funds were awarded (34 CFR 668.164 and 668.165). Distributions to first time borrowers should be 30 days after the first day of classes (34 CFR 685.303). Condition and Context: For 13 of the 25 students selected for testing, a credit balance was late being paid back to the student, a waiver was not obtained, and the College is on the reimbursement payment method. For one of the 25 students selected for testing, disbursement was made to the first time student prior to 30 days after the first day of classes. Our sample was not statistically valid. Cause and Effect: The College experienced several personnel changes in the financial aid office and did not have proper controls in place to monitor these requirements. As a result, the College was holding funds that needed to be returned to the student and not strictly adhering to the rules for first time borrowers. Recommendation: We recommend the College develop sufficient, appropriate internal controls over the disbursement of Title IV funds to students in a timely manner when a credit balance is created on their account and adhere to disbursement rules to first time students. Management Response: Management agrees with this finding. The Office of Financial Aid will continue to run student disbursements on a daily basis. The Vice President of Finance, Operations, and Information Technology and the Director of Financial Operations will enforce policies and procedures to ensure the student refund process is performed and reviewed on a timely basis.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-009: Eligibility ? Significant Deficiency and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 Federal Award Year: June 30, 2022 Criterion: Title IV regulations (34 CFR 630.63) determines the method of calculating the Pell Award for a payment period. Condition and Context: For three of the twenty-five students selected for testing, the Pell Award calculation was not correctly performed, and the students did not receive an adequate amount of Pell Award for the period under audit. Our sample was not statistically valid. Cause and Effect: The College experienced several personnel changes in the financial aid office and did not have proper controls in place to monitor these requirements. As a result, the College did not perform adequate review and approval procedures over the calculation of the Pell Award. Recommendation: We recommend the College develop sufficient, appropriate internal controls over the calculation of the Pell Award for students. Management Response: Management agrees with this finding. The Vice President of Finance, Operations and IT and the Director of Financial Operations will enforce policies and procedures to ensure the Pell Award calculation are accurately performed.
Finding 2022-004: Disbursements to or on Behalf of Students - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: An institution must pay credit balances to students no later than 14 days after the balance occurred if the balance occurred after the first day of class of that payment period, or 14 days after the first day of class if the balance occurred on or before the first day of class. When a valid waiver has been obtained, an institution must pay the remaining balance on loan funds by the end of the loan period and any remaining other Title IV program funds by the end of the last payment period in the award year for which the funds were awarded (34 CFR 668.164 and 668.165). Distributions to first time borrowers should be 30 days after the first day of classes (34 CFR 685.303). Condition and Context: For 13 of the 25 students selected for testing, a credit balance was late being paid back to the student, a waiver was not obtained, and the College is on the reimbursement payment method. For one of the 25 students selected for testing, disbursement was made to the first time student prior to 30 days after the first day of classes. Our sample was not statistically valid. Cause and Effect: The College experienced several personnel changes in the financial aid office and did not have proper controls in place to monitor these requirements. As a result, the College was holding funds that needed to be returned to the student and not strictly adhering to the rules for first time borrowers. Recommendation: We recommend the College develop sufficient, appropriate internal controls over the disbursement of Title IV funds to students in a timely manner when a credit balance is created on their account and adhere to disbursement rules to first time students. Management Response: Management agrees with this finding. The Office of Financial Aid will continue to run student disbursements on a daily basis. The Vice President of Finance, Operations, and Information Technology and the Director of Financial Operations will enforce policies and procedures to ensure the student refund process is performed and reviewed on a timely basis.
Finding 2022-005: Return of Title IV Funds - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Supplemental Education Opportunity Grants, Federal Work Study Program, Federal Pell Grant Program and Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.007, 84.033, 84.063 and 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition and Context: For two out of two students selected for testing, their return was not submitted within the required 45-day window. Our sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the Title IV funds were returned within the required 45 days, and as a result, the funds were not timely remitted. Recommendation: The College should implement a process and related control to ensure that Title IV funds are returned timely to the Department of Education. Management Response: Management agrees with the finding. The Vice President of Finance, Operations, and Information Technology will ensure the implementation of procedures and controls in 2023 to ensure Title IV returns are processed in a timely manner.
Finding 2022-006: Direct Loan Reconciliation - Material Weakness and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criterion: 34 CFR 685.300(b)(5) states that on a monthly basis the College must reconcile institutional records with direct loan fund records received from the Secretary and direct loan disbursement records submitted to and accepted by the Secretary. Condition and Context: Documentation that the required monthly School Account Statement (SAS) reconciliations were not completed for any of the three monthly tested for the year ended June 30, 2022. This sample was not statistically valid. Cause and Effect: The College did not have an adequate control to ensure that the SAS reconciliations were performed and reviewed, and as a result, the College did not perform the required monthly reconciliations which could result in variances between the records of the College and the U.S. Department of Education, which could impact the student. Recommendation: The College should implement a process and related control to ensure that the SAS reconciliations are performed monthly and reviewed in a timely manner by the relevant person and to a sufficient level of detail. Management Response: Management agrees with the finding. The Director of Financial Aid will ensure the implementation of procedures and controls in 2023 to ensure monthly School Account Statements (SAS) are processed and reviewed in a timely manner.
Finding 2022-007: Late Student Status Change Reporting - Significant Deficiency and Noncompliance Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2022 Criterion: Title IV regulations require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the Institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the Institution and who received a loan under Title IV of the Act has changed his or her permanent address. In addition, the Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of controls over applicable compliance requirements. Condition and Context: The change in status for one of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a roster file within 60 days. The sample was not statistically valid. Cause and Effect: The generation of enrollment reports changes is a manual process that, if not performed or reviewed to a sufficient level of detail, is subject to issues with the completeness and accuracy of information in the report. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment statuses, effective dates of enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: The College should develop a way to reliably generate a report that contains exactly the information required for student status changes. The College should review and revise its controls over compliance to ensure that student status changes are reported in a timely manner. Management Response: Management agrees with the finding. The Director of Financial Aid and Registrar will implement procedures and controls in 2023 to ensure student status changes are processed and reviewed in a timely manner.
Finding 2022-008: Improper HEERF Student and Institutional Aid Reporting - Significant Deficiency and Noncompliance Federal Program: COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund - Student and Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Criterion: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all Sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition and Context: There were no student quarterly reports posted to the College's website for the quarters ending September 30, 2021, December 31, 2021, and March 31, 2022 and the institutional quarterly reports were posted late for the quarters ending September 30, 2021, December 31, 2021 and March 31, 2022. Cause and Effect: The College did not have an adequate control to ensure that all of the student quarterly reports were posted to their website or the institutional reports were posted timely to their website, and as a result, the reports were not posted or posted timely, respectively. Recommendation: The College should implement a process and related control to ensure that HEERF reporting requirements are met in a timely manner. Management Response: The Director of Sponsored Programs will ensure the implementation of procedures and controls in 2023 to ensure timely submission of Education Stabilization Funds (ESF) and Higher Education Relief Funds (HEERF) student and institutional quarterly reports are submitted in a timely manner.
Finding 2022-008: Improper HEERF Student and Institutional Aid Reporting - Significant Deficiency and Noncompliance Federal Program: COVID-19 - Education Stabilization Fund - Higher Education Emergency Relief Fund - Student and Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Criterion: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all Sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition and Context: There were no student quarterly reports posted to the College's website for the quarters ending September 30, 2021, December 31, 2021, and March 31, 2022 and the institutional quarterly reports were posted late for the quarters ending September 30, 2021, December 31, 2021 and March 31, 2022. Cause and Effect: The College did not have an adequate control to ensure that all of the student quarterly reports were posted to their website or the institutional reports were posted timely to their website, and as a result, the reports were not posted or posted timely, respectively. Recommendation: The College should implement a process and related control to ensure that HEERF reporting requirements are met in a timely manner. Management Response: The Director of Sponsored Programs will ensure the implementation of procedures and controls in 2023 to ensure timely submission of Education Stabilization Funds (ESF) and Higher Education Relief Funds (HEERF) student and institutional quarterly reports are submitted in a timely manner.