Finding 1218147 (2025-006)

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

AI Summary

  • Core Issue: The College failed to identify students on satisfactory academic progress (SAP) suspension, leading to ineligible students receiving aid.
  • Impacted Requirements: This violates 34 CFR § 668.34(a) and 2 CFR 200.303, which mandate effective internal controls and a proper SAP policy.
  • Recommended Follow-Up: The College should review and improve its SAP processes to ensure compliance and prevent future disbursement errors.

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: Significant Deficiency in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress (SAP) policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards must establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, regulations, and the terms and conditions of the award. Condition: The College did not properly identify students on satisfactory academic progress (SAP) suspension, resulting in disbursement of aid to ineligible students. Questioned Costs: $5,530 Context: During our testing of 60 students, we identified 4 students who were not meeting Satisfactory Academic Progress (SAP) requirements and were not placed on SAP suspension and received aid they were ineligible for. Cause: The college does not have a proper process to ensure students not meeting SAP requirements are not disbursed aid. Effect: Ineligible students received Title IV funds. Repeat Finding: 2024-006. Recommendation: We recommend that the College review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institutions SAP policy. Views of responsible officials: There is no disagreement with the finding.

Corrective Action Plan

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since December 2025, the College has worked with the SIS Managed Services team (Anthology now Ellucian) to update its SAP policy and ensure compliance with federal regulations. The new SAP policy was fully implemented effective during the Winter 2026 term. As an internal control, at the end of each term when SAP is evaluated, the results are pre-screened by the Coordinator of Financial Aid with oversight from the Director of Financial Aid to ensure accuracy before results are posted live in the system. Additionally, the College has clarified its understanding of Anthology’s treatment of students who are newly enrolled at the College or who have changed into a different program version. These students are designated with a not-calculated SAP which represents a blank or null status until the conclusion of the term when the students receive a passing or failing grade and can be evaluated by the SAP standards. Steps also have been taken to ensure that prior enrollments are linked to ensure integrity of the application of SAP standards based on the cumulative pace, GPA and maximum timeframe. As a further measure to ensure the integrity of awarding Title IV funds only to eligible students, the College has placed students with prior ineligible SAP statuses in a hold group within the SIS and identified these students as not meeting Disbursement Approval Criteria (DAC) thus causing any attempt to disburse funds to them to fail. 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

Procurement, Suspension & Debarment Student Financial Aid Eligibility Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

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
  • 1218146 2025-005
    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