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.
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.
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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. 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, 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: There were instances in which the status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Context: In our statistically valid sample of forty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student where the enrollment was not reported timely to NSLDS, eight students where the program enrollment effective date did not match institutions records and three students where the program enrollment status did not match the institutions records. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or 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 the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. 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, 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: There were instances in which the status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Context: In our statistically valid sample of forty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student where the enrollment was not reported timely to NSLDS, eight students where the program enrollment effective date did not match institutions records and three students where the program enrollment status did not match the institutions records. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or 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 the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. 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, 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: There were instances in which the status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Context: In our statistically valid sample of forty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student where the enrollment was not reported timely to NSLDS, eight students where the program enrollment effective date did not match institutions records and three students where the program enrollment status did not match the institutions records. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or 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 the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit 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. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level, as well as the program begin date. 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, 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: There were instances in which the status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Context: In our statistically valid sample of forty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student where the enrollment was not reported timely to NSLDS, eight students where the program enrollment effective date did not match institutions records and three students where the program enrollment status did not match the institutions records. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or 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 the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 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 observable controls to test for the R2T4 process. Questioned costs: None Context: During the testing of R2T4, we tested 23 students. We were unable to test a specific control in place to ensure that any error in the R2T4 process would be prevented and detected in a timely manner as there is only one person involved in the process from start to finish. Cause: There are no procedures to review R2T4 calculations by someone other than the person performing the calculation. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 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 observable controls to test for the R2T4 process. Questioned costs: None Context: During the testing of R2T4, we tested 23 students. We were unable to test a specific control in place to ensure that any error in the R2T4 process would be prevented and detected in a timely manner as there is only one person involved in the process from start to finish. Cause: There are no procedures to review R2T4 calculations by someone other than the person performing the calculation. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 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 observable controls to test for the R2T4 process. Questioned costs: None Context: During the testing of R2T4, we tested 23 students. We were unable to test a specific control in place to ensure that any error in the R2T4 process would be prevented and detected in a timely manner as there is only one person involved in the process from start to finish. Cause: There are no procedures to review R2T4 calculations by someone other than the person performing the calculation. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: 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 observable controls to test for the R2T4 process. Questioned costs: None Context: During the testing of R2T4, we tested 23 students. We were unable to test a specific control in place to ensure that any error in the R2T4 process would be prevented and detected in a timely manner as there is only one person involved in the process from start to finish. Cause: There are no procedures to review R2T4 calculations by someone other than the person performing the calculation. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Views of responsible officials: There is no disagreement with the audit 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: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None Context: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Cause: The College did not have a control in place to ensure timely and accurate reporting to COD. 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 College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.