Audit 54568

FY End
2022-06-30
Total Expended
$2.10M
Findings
4
Programs
5
Organization: Visible Music College (TN)
Year: 2022 Accepted: 2023-03-30
Auditor: Dalcpa

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
58015 2022-002 - - N
58016 2022-001 - Yes N
634457 2022-002 - - N
634458 2022-001 - Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $1.46M Yes 1
84.063 Federal Pell Grant Program $581,494 Yes 1
84.425 Education Stabilization Fund $23,950 Yes 0
84.033 Federal Work-Study Program $15,442 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $15,000 Yes 0

Contacts

Name Title Type
ZLR6RPGEG9M3 Ben Rawlley Auditee
9013813939 David A Levy Auditor
No contacts on file

Notes to SEFA

Accounting Policies: SIGNIFICANT ACCOUNTING POLICIES A. Reporting Entity-The accompanying schedule includes all federal award programs for the fiscalyear ended June 30, 2022. The reporting entity is defined in Notes to Financial Statements as ofJune 30, 2022. B. Basis of presentation-The information in the accompanying schedule of expenditures of federalawards is presented in accordance with the requirements of Title 2 U.S. Code of FederalRegulation Part 200, Uniform Administrative Requirements, Cost Principles, and AuditRequirements for Federal Awards (Uniform Guidance). Because the schedule presents only aselected portion of the operations of Visible Music College, it is not intended to and does notpresent the financial position, changes in net assets or cash flows of Visible Music College. 1. Pursuant to the Uniform Guidance, federal awards are defined as assistance provided by afederal agency, either directly or indirectly, in the form of grants, contracts, cooperativeagreements, loans, loan guarantees, property, interest subsidies, insurance or direct appropriations. 2. Major Programs- The Uniform Guidance establishes the levels of expenditure or expenses to beused in defining major federal financial award programs. Major programs for the school have beenidentified in the attached Schedule of Findings and Questioned costs. C. Basis of Accounting-The information presented in the schedule of expenditures of federalawards is presented on the accrual basis of accounting, which is consistent with the reporting inthe Institutions financial statements. D. Indirect Cost Rate - The school has elected not to use the 10 percent de minimis indirect costrate allowed under Uniform Guidance. E. Subrecipients There were no funds passed through to subrecipients. F. The United States Department of Education performed a program review of the Institution fromSeptember 9, 2019 through September 13, 2019 and issued a report dated March 13, 2020 with 10findings. On June 12, 2020 the Institution submitted an initial limited response (ILR) to theprogram review report challenging several of these findings. As of the date of this report, theDepartment of Education has not issued a response to the ILR. On July 27, 2022 the Institution received a letter from the United States Department of Educationnotifying the Institution of that it had completed its review of the fiscal year ended June 30, 2021audited financial statements and that the composite score was a 0.9. The letter stipulates that theInstitution must either 1) post a letter of credit in the amount of 50% of Title IV funds received or2) post a letter of credit in the amount of 10% of Title IV funds received and be provisionallycertified for a period of up to three complete award years. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate.

Finding Details

Finding 2022-002: NSLDS Status Reporting Error Criteria: In accordance with 34 CFR 682.610 (c), Institutions are to report the enrollment status of students who received Title IV aid to NSLDS. This enrollment information is updated in NSLDS and, as appropriate, is reported to guarantors, lenders, and servicers of federal student loans. A student?s enrollment status determines eligibility for in-school status, deferment and grace periods as well as for the Department?s payment of interest subsidies to loan holders. SSCR/Enrollment Reporting is not only critical for effective administration of the Title IV student loan programs, but is also required so that the Department can engage in budgetary and policy analysis. Condition: One student status was not reported to NSLDS in a timely manner. Cause: The Institution did not follow its ordinary procedures to ensure that NSLDS enrollment reporting was submitted correctly and in a timely manner. Effect: The USDOE does not have timely information pertaining to student's enrollment status which can affect loan deferments among other things. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which NSLDS data for 45 students was reviewed, the students? enrollment status change was not reported to NSLDS in a timely manner. In this instance, the withdrawn status was first reported to NSLDS 205 days after the student?s last date of attendance. Recommendation: We recommend that the Institution enact stronger controls to ensure that all future enrollment reporting is submitted timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Finding 2022-001: Late Return to Title IV (R2T4) Criteria: In accordance with 34 CFR 668.22(1) 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. Condition: The Institution returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds in a timely manner. Effect: The Institution may owe interest on funds returned late. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which 25 students withdrew, the Institution returned the correct amount of Title IV funds beyond the allowable time frame. In this instance, the Institution returned the correct amount of funds 85 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Finding 2022-002: NSLDS Status Reporting Error Criteria: In accordance with 34 CFR 682.610 (c), Institutions are to report the enrollment status of students who received Title IV aid to NSLDS. This enrollment information is updated in NSLDS and, as appropriate, is reported to guarantors, lenders, and servicers of federal student loans. A student?s enrollment status determines eligibility for in-school status, deferment and grace periods as well as for the Department?s payment of interest subsidies to loan holders. SSCR/Enrollment Reporting is not only critical for effective administration of the Title IV student loan programs, but is also required so that the Department can engage in budgetary and policy analysis. Condition: One student status was not reported to NSLDS in a timely manner. Cause: The Institution did not follow its ordinary procedures to ensure that NSLDS enrollment reporting was submitted correctly and in a timely manner. Effect: The USDOE does not have timely information pertaining to student's enrollment status which can affect loan deferments among other things. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which NSLDS data for 45 students was reviewed, the students? enrollment status change was not reported to NSLDS in a timely manner. In this instance, the withdrawn status was first reported to NSLDS 205 days after the student?s last date of attendance. Recommendation: We recommend that the Institution enact stronger controls to ensure that all future enrollment reporting is submitted timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Finding 2022-001: Late Return to Title IV (R2T4) Criteria: In accordance with 34 CFR 668.22(1) 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. Condition: The Institution returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds in a timely manner. Effect: The Institution may owe interest on funds returned late. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which 25 students withdrew, the Institution returned the correct amount of Title IV funds beyond the allowable time frame. In this instance, the Institution returned the correct amount of funds 85 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.