Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting. Questioned costs: None reported. Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred. Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2023-002. Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting. Questioned costs: None reported. Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred. Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2023-002. Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not report COD disbursements with the required 15 days after disbursement for 1 out of 40 disbursements tested. Additionally, we did not note evidence of a key control occurring for COD disbursement reporting. Questioned costs: None reported. Context: During our testing, we noted that one student out of forty did not have their disbursement reported to COD within the required 15 days. Additionally, the University was unable to provide evidence of a key control having occurred. Cause: The University did not have proper procedures in place to identify COD reporting errors and fix them within a timely manner, and did not have evidence of review available. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. View of Responsible Official: The University agrees with the finding.
Criteria: 2 CFR 200.303 includes requirements related to internal controls for federal award programs, including that the Agency must, among other things, “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)”. 2 CFR 200.329(c)(1) includes requirements related to performance reports for federal award programs, including that the IEDC must submit performance reports as required by the Federal award. Non-construction awards under Assistance Listing number 11.307 require recipients of awards on or after June 1, 2020, to submit ED-916 and ED-918. Condition and Context: We noted IEDC submitted the SF-425 Federal Financial Report required under the Economic Adjustment Assistance grant which reported an inaccurate amount of cash receipts during the reporting period identified. The difference noted was not material to the major program. We also reviewed whether performance reports ED-916 and ED-918 required under the Economic Adjustment Assistance were submitted in a timely manner noting the reports were not filed as of the required submission date. There were no questioned costs related to this finding. Cause and Effect: We noted lack of internal controls surrounding the reporting process resulted in key line items in the SF-425 Federal Financial Report to be misstated. The errors were identified subsequent to the submission and corrected in the submission of the final SF-425 Federal Financial Report. We also noted lack of internal controls surrounding the reporting process resulted in performance reports for this federal award to be submitted after the required submission date. Recommendation: We recommend IEDC implement procedures to ensure reports are being reviewed by an individual familiar with the program prior to submission and are being submitted timely and accurately during the reporting period. Views of Responsible Officials and Actions Taken: We agree with the recommendation and as of October 2024 have implemented an additional layer of review, effective for the first round of reports filed for FY2025.
Administration for Children and Families Federal Financial Assistance Listing #93.566, 2301SDRSSS, 10/01/2022 – 9/30/2024 Refugee and Entrant Assistance – State Administered Programs Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We noted the Federal funding Accountability and Transparency Act (FFATA) report filed for Huron School District included the incorrect Subaward Obligation/Action Date within the FFATA Subaward Reporting System. Cause: The Organization included the grant award end date within the reporting system due to misinterpretation of the required FFATA report information. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that the Organization would not be in compliance with the federal award as it relates to reporting. Questioned Costs: None reported. Context/Sampling: No sampling was performed over the FFATA reports. The quantity and subaward obligation errors were noted as follows: see table in report Repeat Finding from Prior Years: Yes, prior year finding 2023-003 Recommendation: We recommend that management review internal control procedures over reporting to ensure accurate information is reported. Views of Responsible Officials: Management is in agreement.
Administration for Children and Families Federal Financial Assistance Listing #93.566, 2202SDRCMA, 10/01/2021 – 9/30/2023 Federal Financial Assistance Listing #93.566, 2302SDRCMA, 10/01/2022 – 9/30/2024 Federal Financial Assistance Listing #93.566, 2402SDRCMA, 10/01/2023 – 9/30/2025 Refugee and Entrant Assistance – State Administered Programs Eligibility Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We noted the following matters during testing which affected 6 participant files; a) One instance in which a family was overpaid for one month due to the family obtaining employment. b) One instance in which a family was underpaid for one month based upon their family size and eligibility for the month. Additionally, documentation was not retained to support one month’s redetermination of eligibility and check copies for two months were not retained to support the payment to the family. c) Three instances in which a family was underpaid based upon their family size and eligibility for the month. d) One instance in which a check was written to a family who out-migrated from the state of South Dakota and the family did not cash the check; however, the expenses remained to be charged under the Refugee Cash Assistance program. Cause: The Organization experienced staff turnover along with an increase in refugee arrivals during the fiscal year creating an increase in the workload of staff members. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that the Organization would provide services to ineligible participants and the Organization would not detect ineligibility in a timely manner. Questioned Costs: $37 Context/Sampling: A nonstatistical sample of 60 participant case files out of more than 250 participant case files were selected for testing which included $152,317 of participant payments out of $694,763. Repeat Finding from Prior Year: Yes, prior year finding 2023-004 Recommendation: We recommend that management review the Organization’s policies, procedures and controls over eligibility with applicable program employees to ensure compliance with the federal program. View of Responsible Officials: Management is in agreement.
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations. Questioned costs: Known $341.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. " Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately. Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding No Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly notify students when loans were credited to student's ledger account. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements. Cause Due to staff turnover, loan notifications were missed being sent out to students. Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat Finding No Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly have documentation of exit counseling notification. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding No Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations. Questioned costs: Known $341.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. " Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately. Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding No Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly notify students when loans were credited to student's ledger account. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements. Cause Due to staff turnover, loan notifications were missed being sent out to students. Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat Finding No Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly have documentation of exit counseling notification. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding No Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations. Questioned costs: Known $341.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. " Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately. Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding No Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly notify students when loans were credited to student's ledger account. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements. Cause Due to staff turnover, loan notifications were missed being sent out to students. Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat Finding No Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly have documentation of exit counseling notification. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding No Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063 Federal Award Identification Number and Year P063P232032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. 34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College under-awarded funds for the Pell Grant. Questioned costs: Known $6,472.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester Effect Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding No Recommendation We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations. Questioned costs: Known $341.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. " Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately. Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding No Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly notify students when loans were credited to student's ledger account. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements. Cause Due to staff turnover, loan notifications were missed being sent out to students. Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat Finding No Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly have documentation of exit counseling notification. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding No Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Award Identification Number and Year P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Cash Management Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have documentation that Direct Loan Reconciliation was performed. Questioned costs: N/A Known Likely Context During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Effect Failure to perform reconciliations timely could result in errors going undetected by student financial aid management. Repeat Finding No Recommendation We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of Responsible Officials Agree
Finding 2024-001 — Late Reporting Submission Compliance and Control over Compliance Finding Significant Deficiency Repeat Finding: No Federal Program Title: U.S. Department of Health and Human Services Social Services Block Grant Assistance Listing Number 93.667 Condition and Context The Agency did not submit quarterly reports within the required time frame (one out of two quarterly reports tested). The quarterly report covered the period from April 1 through June 30, 2024, and was due on July 15, 2024; the Agency submitted the report on July 17, 2024. Criteria The Department of Health and Human Services requires performance reports to be submitted on a quarterly basis within 15 days of the quarter end. 2 CFR Section 200.303 requires entities receiving federal awards to establish and maintain internal controls deigned to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely and accurate posting of reports. Questioned Costs There were no questioned costs with respect to this finding. Cause The Agency did not have effective controls in place to ensure reports were completed and submitted timely. Reports were not reviewed or submitted timely. Effect The untimely submission of reports is not compliant with the requirements of the grant award and could impact future funding. Recommendation We recommend the Agency implement controls to ensure required reports are submitted timely. Views of Responsible Officials We agree with this finding. See corrective action plan.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Test and Provision Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS. Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding No Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations. " Questioned costs: N/A Known Not over $25k Likely See Question Cost Tab Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date. Cause The College was using the incorrect withdraw date Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Test and Provision Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS. Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding No Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations. " Questioned costs: N/A Known Not over $25k Likely See Question Cost Tab Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date. Cause The College was using the incorrect withdraw date Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Test and Provision Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS. Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding No Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations. " Questioned costs: N/A Known Not over $25k Likely See Question Cost Tab Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date. Cause The College was using the incorrect withdraw date Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Test and Provision Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified ten instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and five instance where the enrollment effective date was not reported correctly to NSLDS. Cause The College did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding No Recommendation We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063, 84.007, 84.033, 84.268 Federal Award Identification Number and Year P063P232037 - 2024, P007A233429 - 2024, P033A233429 - 2024, P268K242037 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment The College used the incorrect withdraw date and incorrectly performed the Return of Title IV funds calculation Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition "The College incorrectly calculated Return to Title IV (R2T4) calculations. " Questioned costs: N/A Known Not over $25k Likely See Question Cost Tab Context During our testing of 40 R2T4 calculations, we identified that 5 had mechanically incorrect calculations by using the incorrect withdraw date. Cause The College was using the incorrect withdraw date Effect The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Procurement Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have documentation that sole source justification was provided during the procurement process. Questioned costs: N/A Known Likely Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract. Cause The College did not have proper documentation to support the procurement process was completed prior to purchase. Effect The College could not be in compliance with federal procurement regulations. Repeat Finding No Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Procurement Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have documentation that sole source justification was provided during the procurement process. Questioned costs: N/A Known Likely Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract. Cause The College did not have proper documentation to support the procurement process was completed prior to purchase. Effect The College could not be in compliance with federal procurement regulations. Repeat Finding No Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files. Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Procurement Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.320. In addition, per the Uniform Guidance CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have documentation that sole source justification was provided during the procurement process. Questioned costs: N/A Known Likely Context During our testing of 5 procurement transactions, we identified 3 vendors that had sole source justifications however they were not dated to verify that the documentation was provided prior to entering the contract. Cause The College did not have proper documentation to support the procurement process was completed prior to purchase. Effect The College could not be in compliance with federal procurement regulations. Repeat Finding No Recommendation We recommend the College evaluate its procedures to ensure documentation is properly supported within their procurement files. Views of Responsible Officials Management agrees with this finding.
2024-001: Written Internal Control Policies and Federal Grant Award Procedures Finding Prior Year Findings: Yes, 2023-002 Department Agency: Department of Treasury State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN #21.027 Type of Finding: Significant Deficiency Questioned Costs: None Criteria: Federal regulations 2 CFR 200.303 state that non-Federal entities establish, document and maintain effective internal control over the Federal awards. Internal controls is generally defined as a process effected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Internal control is not one event or circumstance, but a dynamic and iterative process-actions that permeate an entity's activites and are an integral part of the way auditee management runs the entity. Condition: The Town did not have written internal controls and Federal grant award policies in place. Cause and Effect: The Town was in the process of adopting internal control policies but did not have them completed at June 30, 2024. Repeat Finding: Yes Recommendation: We recommend that the Town of Dayton develop and adopt written internal controls and Federal grant award procedures. Response: Please see the last page of this report for the Town's response to this finding.
Finding Number: 2024-001 Finding Type: Federal award finding Federal Assistance Listing No.: 14.267 Program Name: Contiuum of Care Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: Multnomanh County Grant Number: JOHS-SVCSGEN-15516-2023 Federal Award Year: July 1, 2023 through June 30, 2024 Control Deficiency Type: Significant deficiency over compliance Instance of Noncompliance: No Compliance Requirement: Special Tests and Provisions Questioned Costs: None Repeat Finding: N/A Criteria: The Uniform Guidance in 2 CFR 200.303 requires that non-Federal entities receiving federal awards establish and maintain internal controls that provide resaonable assurance that the sub-recipient is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Per 24 CFR 578.51 (g), “HUD will only provide rental assistance for a unit if the rent is reasonable. The recipient or sub-recipient must determine whether the rent charged for the unit receiving rental assistance is reasonable in relation to rents being charged for a comparable unassisted unit, taking into account the location, size, type, quality, amenities, facilities, and management and maintenance of each unit. Reasonable rent must not exceed rents currently being charged by the same owner for comparable unassisted units.” Condition: Out of a non-statistical sample of 40 transactions, we noted two instances in which rent reasonableness determination was not performed, and two instances in which the rent reasonableness determination was calculated using the incorrect information. All of these instances consisted of rent assistance paid for units located outside Multnomah County. Cause: The database used by program staff to perform a rent reasonableness analysis only included zip codes located within Multnomah County. The organization had no clear procedures in place to ascertain that testing of rent reasonableness was performed and documented for units located in areas not included in the County’s database. Effect: The organization may accidently provide rental assistance that is not in compliance with HUD guidelines. Questioned Costs: It was subsequently determined that all rental assistance provided met the resonableness test, and therefore, there are no questioned costs to be reported. Audit Recommendation: We recommend that the organization review and enhance its existing written policies and procedures to ensure the rent reasonableness test and related documentation is performed on all the rental assistance awarded in accordance with the requirements of the federal program. In addition, the policies should include procedures for addressing special circumstances, should they arise. Management’s Response: As of March 16, 2024, all Janus’ Rental Assistance Programming has been consolidated under two experienced Program Directors for whom Rental Assistance administration is a primary program component. Policies and procedures for obtaining required documentation have been updated and include a mandatory documentation checklist submitted together with payment request, and a new policy has been created for the rare circumstances when youth are housed outside our primary service area of Multnomah, Clark or Cowlitz counties.
Criteria or specific requirement: The Code of Federal Regulations,2 CFR 200.332(c) states that the pass through entity must "evaluate each subrecipients fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring." The CFR then states in paragraph (e) that the entity must also "monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and terms and conditions of the subaward. In addition, the Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The College did not have proper monitoring procedures in place to evaluate subrecipients fraud risk and risk of noncompliance and also did not have proper procedures in place to monitor that the subrecipient complied with federal statutes, and regulations. Questioned costs: None Context: During our testing of the one subrecipient in this program. We noted the College did not have policies and procedures to monitor subrecipients fraud risk, risk of noncompliance, and compliance with federal statutes and regulations. There was also no control in place to ensure compliance with subrecipient monitoring requirements. Cause: The College did not have proper monitoring procedures or controls in place to ensure compliance with subrecipient monitoring requirements. Effect: Subrecipients could be noncompliant with federal statutes and the College would be unaware. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures along with an observable control to ensure that subrecipient monitoring requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations,2 CFR 200.332(c) states that the pass through entity must "evaluate each subrecipients fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring." The CFR then states in paragraph (e) that the entity must also "monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and terms and conditions of the subaward. In addition, the Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The College did not have proper monitoring procedures in place to evaluate subrecipients fraud risk and risk of noncompliance and also did not have proper procedures in place to monitor that the subrecipient complied with federal statutes, and regulations. Questioned costs: None Context: During our testing of the one subrecipient in this program. We noted the College did not have policies and procedures to monitor subrecipients fraud risk, risk of noncompliance, and compliance with federal statutes and regulations. There was also no control in place to ensure compliance with subrecipient monitoring requirements. Cause: The College did not have proper monitoring procedures or controls in place to ensure compliance with subrecipient monitoring requirements. Effect: Subrecipients could be noncompliant with federal statutes and the College would be unaware. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures along with an observable control to ensure that subrecipient monitoring requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations,2 CFR 200.332(c) states that the pass through entity must "evaluate each subrecipients fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring." The CFR then states in paragraph (e) that the entity must also "monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and terms and conditions of the subaward. In addition, the Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The College did not have proper monitoring procedures in place to evaluate subrecipients fraud risk and risk of noncompliance and also did not have proper procedures in place to monitor that the subrecipient complied with federal statutes, and regulations. Questioned costs: None Context: During our testing of the one subrecipient in this program. We noted the College did not have policies and procedures to monitor subrecipients fraud risk, risk of noncompliance, and compliance with federal statutes and regulations. There was also no control in place to ensure compliance with subrecipient monitoring requirements. Cause: The College did not have proper monitoring procedures or controls in place to ensure compliance with subrecipient monitoring requirements. Effect: Subrecipients could be noncompliant with federal statutes and the College would be unaware. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures along with an observable control to ensure that subrecipient monitoring requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: During our eligibility testing of forty students, we noted two students that were under awarded in Subsidized loans. Questioned costs: None Context: During our eligibility testing of forty students, we identified two students who were under awarded in Subsidized loans. Cause: For one of the students the College's system applied the scholarship to the students account and incorrectly reduced the students subsidized loan award. For another student the student was packaged incorrectly and had unmet need and should have received a subsidized loan to meet unmet need before being awarded unsubsidized loans. Effect: Students were not awarded all the aid they were eligible for. Repeat Finding: No Recommendation: We recommend that the College review its process for packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: During our eligibility testing of forty students, we noted two students that were under awarded in Subsidized loans. Questioned costs: None Context: During our eligibility testing of forty students, we identified two students who were under awarded in Subsidized loans. Cause: For one of the students the College's system applied the scholarship to the students account and incorrectly reduced the students subsidized loan award. For another student the student was packaged incorrectly and had unmet need and should have received a subsidized loan to meet unmet need before being awarded unsubsidized loans. Effect: Students were not awarded all the aid they were eligible for. Repeat Finding: No Recommendation: We recommend that the College review its process for packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.