2022-003 Student Aid Grants Criteria - When making grants to students under the Education Stabilization Fund - student aid portion, institutions must prioritize students with exceptional need. The Higher Education Emergency Relief Fund III Frequently Asked Questions, question #12 further states that if the institution established preconditions for students to receive emergency financial aid grants (e.g., (1) establishing a minimum GPA, (2) imposing other academic or athletic performance or good standing requirements, (3) requiring continued enrollment in the institution or (4) required the student to first pay any outstanding debt or balance) that results in failure to prioritize students with exceptional need. Condition - During fiscal year 2022, the Institute incurred expenses for student aid grant payments that contained academic, performance or attendance provisions: ? $17,000 of student aid grants established a minimum GPA ? $12,000 of student aid grants included performance measures ? $16,000 of student aid grants were paid to students that had been nominated by high school counselors for attendance at the Institute ? $6,759 of student aid grants were for students with parents who graduated from the institution Effect - As a result of grants containing academic or attendance provisions, students with exceptional need were not prioritized. Cause - The identified non-compliance was caused by the interpretation of how to ?prioritize students with exceptional need.? The root of this cause was the fluid nature of guidance on administrating Educational Stabilization Funds and how the guidance would ultimately be interpreted. Questioned Costs - $51,759 Context - During fiscal year 2022, the Institute incurred expenses for student aid grant payments totaling $275,050. Of this amount, it was noted that student aid grants issued totaling $51,759 contained academic or attendance provisions. Recommendation - We recommend that the Institute establish controls and procedures to ensure that grants to student under the Education Stabilization Fund - student aid portion prioritize students with exceptional need. Response - It is our position that students with an exceptional need were prioritized through the Cares Student Emergency Hardship Grant. Throughout the funding period students with exceptional or acute need have had access to an emergency grant application. Applications are reviewed by a committee and awarded for eligible expenses to students who demonstrate exceptional need. All enrolled students have access to this application. Conclusion - Response accepted.
2022-004 Student Aid Disbursements Criteria - Disbursements made under the student aid portion of the Education Stabilization Fund are required to be made directly to students. The Higher Education Emergency Relief Fund III Frequently Asked Questions, question #11 further states that Institutions may not use the emergency financial aid grants to satisfy a student?s outstanding account balance, unless it has obtained the student?s written (or electronic), affirmative consent. Condition - In 1 of 21 students selected for testing it was noted that a student aid grant was applied to a student?s account balance without written (or electronic), affirmative consent. Effect - As a result of this condition, the student was not given a direct payment for use as emergency relief in response to the effects of coronavirus. Cause - The cause of this noncompliance was a lack of sufficient communication among staff and a lack of prompt corrective action. Recommendation - We recommend the Institute establish controls and procedures to ensure student aid grant payments are made directly to students unless the Institute obtains student?s written (or electronic), affirmative consent to apply the funds to the student?s account. Response - There was some initial confusion over which account these funds were to be applied to. The fund administrator applied the funds to the student HEERF funds rather than the Institutional funds. Upon realization of where the funds originated, the financial aid and fiscal operations departments then generated election forms for students. Since this particular student was no longer enrolled at the college, the election form was not returned. Conclusion - Response accepted.
2022-005 Quarterly Reporting Criteria - Quarterly public reporting for institutional and student aid portion expenses of the Education Stabilization Fund are required to be posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Condition - The Institute stated 3 of 4 quarterly reports selected for testing were not posted to their website within 10 days after the end of the calendar quarter. The Institute stated 1 of the 4 quarterly reports selected for testing was posted timely; however, the Institute was unable to provide information to show the date of the posting to their website. At the time of the audit, all reports were posted on the Institute?s website. Effect - As a result of this condition, the required information was not provided to the public timely and therefore, not in compliance with the grant requirements. Cause - The cause of the lack of timely reporting evidence was due to the untimely submission of the reports. The reports are currently posted and are present in the required locations. Recommendation - We recommend that the Institute establish controls and procedures to ensure quarterly reporting is posted timely in accordance with the grant requirements. Response - Largely, the demands of operating a college during a pandemic, and the constantly changing reporting requirements caused an inappropriate prioritization of the reporting and the documentation of the date of reporting. Conclusion - Response accepted.
2022-005 Quarterly Reporting Criteria - Quarterly public reporting for institutional and student aid portion expenses of the Education Stabilization Fund are required to be posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Condition - The Institute stated 3 of 4 quarterly reports selected for testing were not posted to their website within 10 days after the end of the calendar quarter. The Institute stated 1 of the 4 quarterly reports selected for testing was posted timely; however, the Institute was unable to provide information to show the date of the posting to their website. At the time of the audit, all reports were posted on the Institute?s website. Effect - As a result of this condition, the required information was not provided to the public timely and therefore, not in compliance with the grant requirements. Cause - The cause of the lack of timely reporting evidence was due to the untimely submission of the reports. The reports are currently posted and are present in the required locations. Recommendation - We recommend that the Institute establish controls and procedures to ensure quarterly reporting is posted timely in accordance with the grant requirements. Response - Largely, the demands of operating a college during a pandemic, and the constantly changing reporting requirements caused an inappropriate prioritization of the reporting and the documentation of the date of reporting. Conclusion - Response accepted.
2022-003 Student Aid Grants Criteria - When making grants to students under the Education Stabilization Fund - student aid portion, institutions must prioritize students with exceptional need. The Higher Education Emergency Relief Fund III Frequently Asked Questions, question #12 further states that if the institution established preconditions for students to receive emergency financial aid grants (e.g., (1) establishing a minimum GPA, (2) imposing other academic or athletic performance or good standing requirements, (3) requiring continued enrollment in the institution or (4) required the student to first pay any outstanding debt or balance) that results in failure to prioritize students with exceptional need. Condition - During fiscal year 2022, the Institute incurred expenses for student aid grant payments that contained academic, performance or attendance provisions: ? $17,000 of student aid grants established a minimum GPA ? $12,000 of student aid grants included performance measures ? $16,000 of student aid grants were paid to students that had been nominated by high school counselors for attendance at the Institute ? $6,759 of student aid grants were for students with parents who graduated from the institution Effect - As a result of grants containing academic or attendance provisions, students with exceptional need were not prioritized. Cause - The identified non-compliance was caused by the interpretation of how to ?prioritize students with exceptional need.? The root of this cause was the fluid nature of guidance on administrating Educational Stabilization Funds and how the guidance would ultimately be interpreted. Questioned Costs - $51,759 Context - During fiscal year 2022, the Institute incurred expenses for student aid grant payments totaling $275,050. Of this amount, it was noted that student aid grants issued totaling $51,759 contained academic or attendance provisions. Recommendation - We recommend that the Institute establish controls and procedures to ensure that grants to student under the Education Stabilization Fund - student aid portion prioritize students with exceptional need. Response - It is our position that students with an exceptional need were prioritized through the Cares Student Emergency Hardship Grant. Throughout the funding period students with exceptional or acute need have had access to an emergency grant application. Applications are reviewed by a committee and awarded for eligible expenses to students who demonstrate exceptional need. All enrolled students have access to this application. Conclusion - Response accepted.
2022-004 Student Aid Disbursements Criteria - Disbursements made under the student aid portion of the Education Stabilization Fund are required to be made directly to students. The Higher Education Emergency Relief Fund III Frequently Asked Questions, question #11 further states that Institutions may not use the emergency financial aid grants to satisfy a student?s outstanding account balance, unless it has obtained the student?s written (or electronic), affirmative consent. Condition - In 1 of 21 students selected for testing it was noted that a student aid grant was applied to a student?s account balance without written (or electronic), affirmative consent. Effect - As a result of this condition, the student was not given a direct payment for use as emergency relief in response to the effects of coronavirus. Cause - The cause of this noncompliance was a lack of sufficient communication among staff and a lack of prompt corrective action. Recommendation - We recommend the Institute establish controls and procedures to ensure student aid grant payments are made directly to students unless the Institute obtains student?s written (or electronic), affirmative consent to apply the funds to the student?s account. Response - There was some initial confusion over which account these funds were to be applied to. The fund administrator applied the funds to the student HEERF funds rather than the Institutional funds. Upon realization of where the funds originated, the financial aid and fiscal operations departments then generated election forms for students. Since this particular student was no longer enrolled at the college, the election form was not returned. Conclusion - Response accepted.
2022-005 Quarterly Reporting Criteria - Quarterly public reporting for institutional and student aid portion expenses of the Education Stabilization Fund are required to be posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Condition - The Institute stated 3 of 4 quarterly reports selected for testing were not posted to their website within 10 days after the end of the calendar quarter. The Institute stated 1 of the 4 quarterly reports selected for testing was posted timely; however, the Institute was unable to provide information to show the date of the posting to their website. At the time of the audit, all reports were posted on the Institute?s website. Effect - As a result of this condition, the required information was not provided to the public timely and therefore, not in compliance with the grant requirements. Cause - The cause of the lack of timely reporting evidence was due to the untimely submission of the reports. The reports are currently posted and are present in the required locations. Recommendation - We recommend that the Institute establish controls and procedures to ensure quarterly reporting is posted timely in accordance with the grant requirements. Response - Largely, the demands of operating a college during a pandemic, and the constantly changing reporting requirements caused an inappropriate prioritization of the reporting and the documentation of the date of reporting. Conclusion - Response accepted.
2022-005 Quarterly Reporting Criteria - Quarterly public reporting for institutional and student aid portion expenses of the Education Stabilization Fund are required to be posted to the institution?s primary website no later than 10 days after the end of each calendar quarter. Condition - The Institute stated 3 of 4 quarterly reports selected for testing were not posted to their website within 10 days after the end of the calendar quarter. The Institute stated 1 of the 4 quarterly reports selected for testing was posted timely; however, the Institute was unable to provide information to show the date of the posting to their website. At the time of the audit, all reports were posted on the Institute?s website. Effect - As a result of this condition, the required information was not provided to the public timely and therefore, not in compliance with the grant requirements. Cause - The cause of the lack of timely reporting evidence was due to the untimely submission of the reports. The reports are currently posted and are present in the required locations. Recommendation - We recommend that the Institute establish controls and procedures to ensure quarterly reporting is posted timely in accordance with the grant requirements. Response - Largely, the demands of operating a college during a pandemic, and the constantly changing reporting requirements caused an inappropriate prioritization of the reporting and the documentation of the date of reporting. Conclusion - Response accepted.