Finding 1218146 (2025-005)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-22

AI Summary

  • Core Issue: The College failed to send exit counseling notifications to students who graduated or withdrew, violating federal requirements.
  • Impacted Requirements: Noncompliance with 34 CFR § 682.604 and 2 CFR 200.303 regarding exit counseling for Stafford Loan borrowers.
  • Recommended Follow-Up: Revise processes and controls to ensure timely exit counseling notifications are sent to all affected students.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance; Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 682.604) states 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, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program that the home institution approves for credit, written counseling materials may be provided by mail within 30 days after the student borrower completes the program. If a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Additionally, 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 send exit counseling notifications to students who graduated or withdrew during the fiscal year. Questioned Costs: None Context: During our eligibility testing, it was noted 6 of 6 students who were in our eligibility sample and either graduated or withdrew did not receive exit counseling notifications. Cause: The College did have a process within its system to send out exit counseling notifications, but it was not set up properly and students were not being notified of exit counseling requirements. The College did not have proper controls in place ensure exit counseling notifications were being sent out. Effect: The College is not in compliance with Department of Education requirements over exit counseling. Repeat Finding: No. Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdraw students throughout the year. Views of responsible officials: There is no disagreement with the finding.

Corrective Action Plan

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since August 2025, the College has taken steps in conjunction with its SIS Managed Services team (Anthology) to establish an automated process to notify graduate/withdrawn students to complete the Exit Counseling requirement. Since then the Director of Financial Aid has been spot-checking the notifications to ensure that the exit counseling notification is being triggered for withdrawn students. Going forward, the Financial Aid Office will use the Task Function in Anthology to confirm that the notification has been sent and close the task which will be timestamped with the name of the reviewer. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility Material Weakness

Other Findings in this Audit

  • 1218125 2025-001
    Material Weakness Repeat
  • 1218126 2025-002
    Material Weakness Repeat
  • 1218127 2025-003
    Material Weakness Repeat
  • 1218128 2025-004
    Material Weakness Repeat
  • 1218129 2025-005
    Material Weakness Repeat
  • 1218130 2025-006
    Material Weakness Repeat
  • 1218131 2025-001
    Material Weakness Repeat
  • 1218132 2025-002
    Material Weakness Repeat
  • 1218133 2025-003
    Material Weakness Repeat
  • 1218134 2025-004
    Material Weakness Repeat
  • 1218135 2025-005
    Material Weakness Repeat
  • 1218136 2025-006
    Material Weakness Repeat
  • 1218137 2025-001
    Material Weakness Repeat
  • 1218138 2025-002
    Material Weakness Repeat
  • 1218139 2025-003
    Material Weakness Repeat
  • 1218140 2025-004
    Material Weakness Repeat
  • 1218141 2025-005
    Material Weakness Repeat
  • 1218142 2025-006
    Material Weakness Repeat
  • 1218143 2025-001
    Material Weakness Repeat
  • 1218144 2025-003
    Material Weakness Repeat
  • 1218145 2025-004
    Material Weakness Repeat
  • 1218147 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.52M
84.268 Federal Direct Student Loans $757,131
93.575 Child Care and Development Block Grant $708,279
84.031 Building Equitable Access and Success Project (EASE) $517,378
11.307 COVID-19 Economic Adjustment Assistance $475,788
11.617 Congressionally Identified Projects Program (CIPP) $310,585
17.258 WIOA Adult Program $171,909
84.002 Adult Education - Basic Grants to States $155,735
17.259 WIOA Youth Activities $142,320
47.076 STEM Education (formerly Education and Human Resources) $138,719
21.027 COVID 19 State and Local Fiscal Recovery Funds - Prosperity 10k $109,170
21.027 COVID-19-ESOL Fiscal Recovery Funds $99,596
17.278 WIOA Dislocated Worker Formula Grants $91,599
21.027 COVID-19 State and Local Fiscal Recovery Funds $62,351
84.007 Federal Supplemental Educational Opportunity Grants $58,050
21.027 COVID 19 State and Local Fiscal Recovery Funds - Ben Nav $32,805
59.037 Development Center Network Office: Small Business Development Center $31,790
84.033 Federal Work-Study Program $24,808
17.277 WIOA National Dislocated Worker Grants / WIA National Emergency Grants $24,232
15.228 BLM Fuels Management and Community Fire Assistance Program Activities $19,914
21.027 COVID 19 State and Local Fiscal Recovery Funds - EOWP Reentry $7,175