Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded
Material Weakness in Internal Controls over Compliance and Noncompliance
Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program.
Condition: During testing over the eligibility requirements, the following deficiencies were noted:
•2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862.
•7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need.
•5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool.
Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need.
Effect: Students were not awarded the proper amount of aid.
Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded.
Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the students with errors be corrected.
Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
2022-2023 Award Year
Cash Management – Reconciliations (Direct Loan)
Significant Deficiency in Internal Controls over Compliance
Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of Direct loans. Presentation College is required to reconcile the monthly School Account Statement (SAS) data file to the institution’s financial records.
Condition: When testing cash management related to reconciliations, we noted the following:
•2 of the 12 monthly SAS reconciliations were not completed by Presentation College.
Cause: Lack of oversight of the monthly reconciliation control resulted in 2 months of reconciliations that were not performed and variances/discrepancies that were not investigated.
Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution’s records.
Questioned Costs: None reported.
Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the College complete one final reconciliation to COD for fiscal year 2023.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Special Tests and Provisions – Enrollment Reporting
Significant Deficiency in Internal Controls over Compliance
Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for Presentation College’s participation in the Direct loan program with regard to enrollment reporting requirements.
Condition: During testing of enrollment reporting, the following deficiencies were noted:
•7 of 19 students were not reported to NSDLS with changes in effective dates and enrollment statuses,and the certification dates were not within 60 days of the changes.
•8 of 19 students were reported to NSLDS with incorrect program begin dates.
Cause: Regarding other reporting issues, errors in information were caused by entry errors by the various departments using incorrect dates or programs. That information is then used to report to NSLDS; therefore, information was reported incorrectly. Regarding the incorrect effective dates and statuses, the College only reporting a portion of students with May graduation dates to NSLDS. Subsequent to the error being noted, the College has completed the full reporting for May graduates.
Effect: The errors result in information being reported incorrectly.
Questioned Costs: None.
Context/Sampling: A nonstatistical sample of 19 students out of 63 students with a change in status were selected for testing of enrollment reporting requirement.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend a final review of status changes for fiscal year 2023 be completed so ensure all changes were properly reported to NSLDS prior to the College closure.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded
Material Weakness in Internal Controls over Compliance and Noncompliance
Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program.
Condition: During testing over the eligibility requirements, the following deficiencies were noted:
•2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862.
•7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need.
•5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool.
Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need.
Effect: Students were not awarded the proper amount of aid.
Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded.
Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the students with errors be corrected.
Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.038 – Federal Perkins Loan Program
Unknown Award Year
Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention –
Significant Deficiency in Internal Controls over Compliance
Criteria: As required by the Department of Education, institutions are required to maintain original proper records for various required timeframes after loans or paid off, forgiven or cancelled.
Condition: Presentation College did not maintain all records as required under the program and, as a result, subsequent to year-end, the College was required to buy back specific Perkins Loans that did not have proper documentation maintained.
Cause: The College has seen significant turnover in the financial aid director role for many years and not all documentation was maintained with that turnover.
Effect: The College was required to buy back a portion of the Perkins Loans.
Questioned Costs: None
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: Based on the College closure, the College has liquated the Federal Perkins Loan Program and no further corrective action is needed with this finding.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded
Material Weakness in Internal Controls over Compliance and Noncompliance
Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program.
Condition: During testing over the eligibility requirements, the following deficiencies were noted:
•2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862.
•7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need.
•5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool.
Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need.
Effect: Students were not awarded the proper amount of aid.
Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded.
Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the students with errors be corrected.
Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Special Tests and Provisions – Enrollment Reporting
Significant Deficiency in Internal Controls over Compliance
Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for Presentation College’s participation in the Direct loan program with regard to enrollment reporting requirements.
Condition: During testing of enrollment reporting, the following deficiencies were noted:
•7 of 19 students were not reported to NSDLS with changes in effective dates and enrollment statuses,and the certification dates were not within 60 days of the changes.
•8 of 19 students were reported to NSLDS with incorrect program begin dates.
Cause: Regarding other reporting issues, errors in information were caused by entry errors by the various departments using incorrect dates or programs. That information is then used to report to NSLDS; therefore, information was reported incorrectly. Regarding the incorrect effective dates and statuses, the College only reporting a portion of students with May graduation dates to NSLDS. Subsequent to the error being noted, the College has completed the full reporting for May graduates.
Effect: The errors result in information being reported incorrectly.
Questioned Costs: None.
Context/Sampling: A nonstatistical sample of 19 students out of 63 students with a change in status were selected for testing of enrollment reporting requirement.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend a final review of status changes for fiscal year 2023 be completed so ensure all changes were properly reported to NSLDS prior to the College closure.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded
Material Weakness in Internal Controls over Compliance and Noncompliance
Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program.
Condition: During testing over the eligibility requirements, the following deficiencies were noted:
•2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862.
•7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need.
•5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool.
Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need.
Effect: Students were not awarded the proper amount of aid.
Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded.
Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the students with errors be corrected.
Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
2022-2023 Award Year
Cash Management – Reconciliations (Direct Loan)
Significant Deficiency in Internal Controls over Compliance
Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of Direct loans. Presentation College is required to reconcile the monthly School Account Statement (SAS) data file to the institution’s financial records.
Condition: When testing cash management related to reconciliations, we noted the following:
•2 of the 12 monthly SAS reconciliations were not completed by Presentation College.
Cause: Lack of oversight of the monthly reconciliation control resulted in 2 months of reconciliations that were not performed and variances/discrepancies that were not investigated.
Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution’s records.
Questioned Costs: None reported.
Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the College complete one final reconciliation to COD for fiscal year 2023.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Special Tests and Provisions – Enrollment Reporting
Significant Deficiency in Internal Controls over Compliance
Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for Presentation College’s participation in the Direct loan program with regard to enrollment reporting requirements.
Condition: During testing of enrollment reporting, the following deficiencies were noted:
•7 of 19 students were not reported to NSDLS with changes in effective dates and enrollment statuses,and the certification dates were not within 60 days of the changes.
•8 of 19 students were reported to NSLDS with incorrect program begin dates.
Cause: Regarding other reporting issues, errors in information were caused by entry errors by the various departments using incorrect dates or programs. That information is then used to report to NSLDS; therefore, information was reported incorrectly. Regarding the incorrect effective dates and statuses, the College only reporting a portion of students with May graduation dates to NSLDS. Subsequent to the error being noted, the College has completed the full reporting for May graduates.
Effect: The errors result in information being reported incorrectly.
Questioned Costs: None.
Context/Sampling: A nonstatistical sample of 19 students out of 63 students with a change in status were selected for testing of enrollment reporting requirement.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend a final review of status changes for fiscal year 2023 be completed so ensure all changes were properly reported to NSLDS prior to the College closure.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded
Material Weakness in Internal Controls over Compliance and Noncompliance
Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program.
Condition: During testing over the eligibility requirements, the following deficiencies were noted:
•2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862.
•7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need.
•5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool.
Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need.
Effect: Students were not awarded the proper amount of aid.
Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded.
Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the students with errors be corrected.
Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.038 – Federal Perkins Loan Program
Unknown Award Year
Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention –
Significant Deficiency in Internal Controls over Compliance
Criteria: As required by the Department of Education, institutions are required to maintain original proper records for various required timeframes after loans or paid off, forgiven or cancelled.
Condition: Presentation College did not maintain all records as required under the program and, as a result, subsequent to year-end, the College was required to buy back specific Perkins Loans that did not have proper documentation maintained.
Cause: The College has seen significant turnover in the financial aid director role for many years and not all documentation was maintained with that turnover.
Effect: The College was required to buy back a portion of the Perkins Loans.
Questioned Costs: None
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No
Recommendation: Based on the College closure, the College has liquated the Federal Perkins Loan Program and no further corrective action is needed with this finding.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded
Material Weakness in Internal Controls over Compliance and Noncompliance
Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program.
Condition: During testing over the eligibility requirements, the following deficiencies were noted:
•2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862.
•7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need.
•5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool.
Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need.
Effect: Students were not awarded the proper amount of aid.
Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded.
Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880.
Repeat Finding from Prior Year(s): Yes.
Recommendation: Based on the announced College closure, we recommend the students with errors be corrected.
Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Department of Education
Student Financial Aid Cluster
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.063 – Federal Pell Grant Program
2022-2023 Award Year
Special Tests and Provisions – Enrollment Reporting
Significant Deficiency in Internal Controls over Compliance
Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for Presentation College’s participation in the Direct loan program with regard to enrollment reporting requirements.
Condition: During testing of enrollment reporting, the following deficiencies were noted:
•7 of 19 students were not reported to NSDLS with changes in effective dates and enrollment statuses,and the certification dates were not within 60 days of the changes.
•8 of 19 students were reported to NSLDS with incorrect program begin dates.
Cause: Regarding other reporting issues, errors in information were caused by entry errors by the various departments using incorrect dates or programs. That information is then used to report to NSLDS; therefore, information was reported incorrectly. Regarding the incorrect effective dates and statuses, the College only reporting a portion of students with May graduation dates to NSLDS. Subsequent to the error being noted, the College has completed the full reporting for May graduates.
Effect: The errors result in information being reported incorrectly.
Questioned Costs: None.
Context/Sampling: A nonstatistical sample of 19 students out of 63 students with a change in status were selected for testing of enrollment reporting requirement.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend a final review of status changes for fiscal year 2023 be completed so ensure all changes were properly reported to NSLDS prior to the College closure.
Views of Responsible Officials: Management agrees with the finding.
Department of Education
Student Financial Aid Cluster
CFDA # 84.033 – Federal Work Study Program
CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG)
CFDA # 84.063 – Federal Pell Grant Program
CFDA # 84.268 – Federal Direct Student Loans
CFDA # 84.038 – Federal Perkins Loan Program
2022-2023 Award Year
Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP).
Significant Deficiency in Internal Controls over Compliance
Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection.
Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7.
Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP.
Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported.
Questioned Costs: None.
Context/Sampling: Sampling was not used.
Repeat Finding from Prior Year(s): No.
Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports.
Views of Responsible Officials: Management agrees with the finding.