EIN: 030179403
UEI: UX4CNQ22L1A4
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 1, 2026 (36 days from today).
What is a management decision? →Criteria Requirement: Institutions are required to report enrollment information under the Federal Pell Grant 34 CFR 690.83 (b)(2)) and the Federal Direct loan program (34 CFR 685.309) via the National Student Loan Data System (NSLDS) Institutions must review, update and certify student enrollment statues, program information and effective dates that appear on the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context: During our audit, we found one (1) of sixty (60) students selected for testing whose change in enrollment status from full time to withdrawn was not transmitted to NSLDS timely. The College reported the withdrawn status change for this student 85 days after they became aware of the status change.Cause and Effect: The condition resulted from the College’s internal controls not being designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is a repeat finding. Refer to prior year finding 2024-001. Recommendation: We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day timeframe. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected.
Show full finding ▾Hide full finding ▴Criteria Requirement: Institutions are required to report enrollment information under the Federal Pell Grant 34 CFR 690.83 (b)(2)) and the Federal Direct loan program (34 CFR 685.309) via the National Student Loan Data System (NSLDS) Institutions must review, update and certify student enrollment statues, program information and effective dates that appear on the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context: During our audit, we found one (1) of sixty (60) students selected for testing whose change in enrollment status from full time to withdrawn was not transmitted to NSLDS timely. The College reported the withdrawn status change for this student 85 days after they became aware of the status change.Cause and Effect: The condition resulted from the College’s internal controls not being designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is a repeat finding. Refer to prior year finding 2024-001. Recommendation: We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day timeframe. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected.
The College agrees with this finding. The Registrar’s Office will proactively report withdrawals from the College between academic semesters manually to the National Student Clearinghouse (NSC) in a timely manner to ensure that NSLDS receives those status changes within the required 60-day window. The Registrar has worked with IT to create a report to assist in identifying all withdrawals that are processed between terms. Staff now uses this report to crosscheck status changes reported to the NSC. This is a repeat finding due to the audit timing. The issue was identified in FY24, and by the time the issue was identified related to the FY24 audit, the FY25 academic year was well underway. The corrective action was implemented in spring/summer of calendar 2025, and the reporting to NCS will be timely for FY26.
2024-001
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
Criteria Requirement: According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half -time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non_x0002_Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context: During our audit we found three (3) of forty (40) students selected for testing whose change in enrollment status from full time to withdrawn was not transmitted to NSLDS timely. The College reported the withdrawn status changes for these three students 61-65 days after they became aware of the status change. In addition, of these three students, the effective dates for two of the students were reported as 12/15/2023, however the effective date per supporting documentation was 12/16/2023. Cause and Effect: The condition resulted from the College’s internal controls not being designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day time frame. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected.
Show full finding ▾Hide full finding ▴Criteria Requirement: According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half -time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non_x0002_Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context: During our audit we found three (3) of forty (40) students selected for testing whose change in enrollment status from full time to withdrawn was not transmitted to NSLDS timely. The College reported the withdrawn status changes for these three students 61-65 days after they became aware of the status change. In addition, of these three students, the effective dates for two of the students were reported as 12/15/2023, however the effective date per supporting documentation was 12/16/2023. Cause and Effect: The condition resulted from the College’s internal controls not being designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day time frame. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected.
The College agrees with this finding. The Registrar’s Office will proactively report withdrawals from the College between academic semesters manually to the National Student Clearinghouse (NSC) in a timely manner to ensure that NSLDS receives those status changes within the required 60-day window. The Registrar will work with IT to create a report to assist in identifying all withdrawals that are processed between terms. Staff will use this report to crosscheck status changes reported to the NSC. The Registrar’s Office will follow up with the Audit Support division of the NSC regarding previous guidance on effective dating of withdrawals. The NSC’s directive to use the day after the final date of a completed term seems to contradict the effective date that the Clearinghouse automatically assigns when a student is not reported for the subsequent term.
Criteria Requirement: Institutions must submit Direct Loan and Pell origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than 7 calendars days prior to the disbursement date under the Advance Payment method. The disbursement record reports the actual disbursement records and returns acknowledgements to the institution. The acknowledgements identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement; or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context: The College disbursed Pell grant funds for students who had a C-flag on their account related to citizenship issue on the FAFSA, which were then rejected by COD due to this citizenship issue on FAFSA. During our audit we found one (1) of seventy-nine (79) Pell disbursements selected for testing, was not reported to the COD website within the 15-day timeframe as required by Federal regulations. The submission date was 27 days after the Pell grant was disbursed. Based on the College’s analysis, there were seven (7) other students whose Pell grant disbursements were not reported to the COD website within the required 15-day timeframe. Cause and Effect: The cause of the condition found was deficient internal controls over the timely submission of data submitted to COD. Specifically, the students identified all had C-flags on their ISIR related to citizenship issues on the FAFSA, which were not resolved prior to disbursement and as such were rejected by COD during the reporting period until the C-flag was resolved. The effect of the condition found is that data submitted to COD is not done timely. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College review the policies and procedures in place for disbursing Pell grant funds, where students have C-flags and submission of data to COD to ensure timely information is reported to COD, as required under Federal regulations
Show full finding ▾Hide full finding ▴Criteria Requirement: Institutions must submit Direct Loan and Pell origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than 7 calendars days prior to the disbursement date under the Advance Payment method. The disbursement record reports the actual disbursement records and returns acknowledgements to the institution. The acknowledgements identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement; or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly or may set up their own system to ensure that changes are reported in a timely manner. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context: The College disbursed Pell grant funds for students who had a C-flag on their account related to citizenship issue on the FAFSA, which were then rejected by COD due to this citizenship issue on FAFSA. During our audit we found one (1) of seventy-nine (79) Pell disbursements selected for testing, was not reported to the COD website within the 15-day timeframe as required by Federal regulations. The submission date was 27 days after the Pell grant was disbursed. Based on the College’s analysis, there were seven (7) other students whose Pell grant disbursements were not reported to the COD website within the required 15-day timeframe. Cause and Effect: The cause of the condition found was deficient internal controls over the timely submission of data submitted to COD. Specifically, the students identified all had C-flags on their ISIR related to citizenship issues on the FAFSA, which were not resolved prior to disbursement and as such were rejected by COD during the reporting period until the C-flag was resolved. The effect of the condition found is that data submitted to COD is not done timely. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College review the policies and procedures in place for disbursing Pell grant funds, where students have C-flags and submission of data to COD to ensure timely information is reported to COD, as required under Federal regulations
Corrective Action Plan: The College agrees with this finding. After disbursing aid for the first time in the Fall 2023 semester and sending Pell origination and disbursement records to COD, the College ran the Pell COD Reject Report (PCRR) in Colleague to identify records that COD had rejected. COD identified 8 students whose Pell disbursement was rejected due to citizenship status issues. These files were reviewed and it was identified that a required field in Colleague was not populated correctly to indicate to COD that the citizenship issue had been reviewed by collecting the required documentation from the student. The files were being reviewed and updates were made in Colleague but not within the 15-day window. Procedure notes have been updated and training has occurred to ensure all relevant personnel understand the process and know where to make the appropriate updates in Colleague when reviewing citizenship documents. Status of Correction Action: Completed
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
Compliance Requirements: Gramm-Leach Bliley Act – Student Information Security Condition or Requirement: The Gramm-Leach-Bliley Act (GLBA) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The written information security program for institutions must address the following seven elements: 1.) Designate a qualified individual responsible for overseeing and implementing the institution’s information security program and enforcing the information security program in compliance. 2.) Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution) that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. 3.) Provides for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment. At a minimum, the institution’s written information security program must address the implementation of the following eight minimum safeguards within the written information security program: i. Implement and periodically review access controls. ii. Conduct a periodic inventory of data, noting where it’s collected, stored, or transmitted. iii. Encrypt customer information on the institution’s system and when it’s in transit. iv. Assess apps developed by the institution. v. Implement multi-factor authentication for anyone accessing customer information on the institution’s system. vi. Dispose of customer information securely vii. Anticipate and evaluate changes to the information system or network. viii. Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. 4.) Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. 5.) Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. 6.) Addresses how the institution will oversee its information system service providers. 7.) Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the institution’s information security program. Condition and Context: The OMB Compliance Supplement requires auditors to verify that the institution has designated a qualified individual to oversee the information security program to and verify the institution has a written information security program that addresses the seven required elements. During our testwork over element 3, we noted that the College’s written information security program did not include information related to conducting periodic inventory of data, noting where it’s collected, stored, or transmitted. Cause and Effect: The cause of the condition found was due to lack of policies and procedures in place to ensure the written information security program addressed the required seven elements, which includes eight minimum safeguards. The effect of the condition found is that the College may not have appropriately designed and implemented safeguards to control the risks identified by the College through its risk assessment. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College conducts periodic inventory of data and ensure it’s written information security program includes the requirement to conduct periodic inventory of data, noting where it’s collected, stored, or transmitted.
Show full finding ▾Hide full finding ▴Compliance Requirements: Gramm-Leach Bliley Act – Student Information Security Condition or Requirement: The Gramm-Leach-Bliley Act (GLBA) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The written information security program for institutions must address the following seven elements: 1.) Designate a qualified individual responsible for overseeing and implementing the institution’s information security program and enforcing the information security program in compliance. 2.) Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information (as the term customer information applies to the institution) that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. 3.) Provides for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment. At a minimum, the institution’s written information security program must address the implementation of the following eight minimum safeguards within the written information security program: i. Implement and periodically review access controls. ii. Conduct a periodic inventory of data, noting where it’s collected, stored, or transmitted. iii. Encrypt customer information on the institution’s system and when it’s in transit. iv. Assess apps developed by the institution. v. Implement multi-factor authentication for anyone accessing customer information on the institution’s system. vi. Dispose of customer information securely vii. Anticipate and evaluate changes to the information system or network. viii. Maintain a log of authorized users’ activity and keep an eye out for unauthorized access. 4.) Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. 5.) Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. 6.) Addresses how the institution will oversee its information system service providers. 7.) Provides for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact the institution’s information security program. Condition and Context: The OMB Compliance Supplement requires auditors to verify that the institution has designated a qualified individual to oversee the information security program to and verify the institution has a written information security program that addresses the seven required elements. During our testwork over element 3, we noted that the College’s written information security program did not include information related to conducting periodic inventory of data, noting where it’s collected, stored, or transmitted. Cause and Effect: The cause of the condition found was due to lack of policies and procedures in place to ensure the written information security program addressed the required seven elements, which includes eight minimum safeguards. The effect of the condition found is that the College may not have appropriately designed and implemented safeguards to control the risks identified by the College through its risk assessment. Identification of Questioned Costs: None. Whether the Sampling was a Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College conducts periodic inventory of data and ensure it’s written information security program includes the requirement to conduct periodic inventory of data, noting where it’s collected, stored, or transmitted.
The College agrees with this finding. Management is in the process of remediating this policy omission and will implement and document the periodic inventory of customer data, including where it’s collected, stored or transmitted. The College expects to have this completed by June 30, 2024. Going forward the Information Technology department will periodically review the inventory of customer data and update as necessary.
FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.
Of the total HEERF III Institutional expenditures of $1,467,000, the College claimed $1,061,426 as lost room and board revenue for the year ended June 30, 2022. In connection with our audit, the College provided us with a listing of lost room and board revenue totaling $1,392,505 that was claimed for both HEERF III institutional funds as well as a COVID-19 relief grant provided by the State of Vermont. Since the population was not segregated between HEERF funds and the State grant, we subjected the total lost room and board revenue detail to our allowability procedures. During our testwork, we identified 3 students in our sample of 25, that attended and paid room & board for a portion of the semester; however, the College included the full semester amount of room and board in their lost room and board revenue detail. We also noted 1 student in our sample of 25 where the incorrect room & board rate was used to calculate the lost revenue.
Show full finding ▾Hide full finding ▴Of the total HEERF III Institutional expenditures of $1,467,000, the College claimed $1,061,426 as lost room and board revenue for the year ended June 30, 2022. In connection with our audit, the College provided us with a listing of lost room and board revenue totaling $1,392,505 that was claimed for both HEERF III institutional funds as well as a COVID-19 relief grant provided by the State of Vermont. Since the population was not segregated between HEERF funds and the State grant, we subjected the total lost room and board revenue detail to our allowability procedures. During our testwork, we identified 3 students in our sample of 25, that attended and paid room & board for a portion of the semester; however, the College included the full semester amount of room and board in their lost room and board revenue detail. We also noted 1 student in our sample of 25 where the incorrect room & board rate was used to calculate the lost revenue.
Management has reviewed the process to determine the root cause of how the incorrect data was included in the original list of lost housing revenue. Through investigation with the Residential Life Department, it was found that the source used to identify the original population was the system used to manage student housing assignments, rather than the student billing sub-ledger, which is the system of record. To establish confidence, an independent query was performed by the Institutional Research (IR) Department. IR has extensive technical knowledge of the Colleague system. The results of that query was then compared and reconciled to the original data set. The final analysis identified $108,056 of overstated lost housing revenue, inclusive of the 4 students identified by KPMG, reducing the lost housing revenue reported from $1,392,505 to $1,284,449. The amount of lost housing revenue allocated to HEERF was $1,061,426. Federal funds were not overdrawn by this misstatement of lost housing revenue. Going forward the Finance Department will strengthen the analysis of student data by engaging Institutional Research to validate data queries of student system.
FAC accepted this audit on May 25, 2022 — management decision was due November 25, 2022.
During our testwork, we identified an issue where the College submitted the direct lending disbursements via COD; however, they were rejected by COD due to a mismatch in the loan origination fee, as the loans were prepared using the loan origination fee effective prior to October 1, 2020, but reported to COD after October 1, 2020. This issue impacted several compliance requirements. During our testwork over Federal Direct Lending Reporting, we noted that for 7 of the 40 students selected, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations as a result of the loan origination fee issue. For these submissions, we noted that the submission dates ranged from 57 to 96 days, after the loans were reprocessed to update the loan origination fee amount. Based on the College?s analysis, the loan origination fee issue impacted 98 students, which resulted in the disbursement data for 98 students totaling $351,879 in loans not being reported to the COD website within the 15-day timeframe.
Show full finding ▾Hide full finding ▴During our testwork, we identified an issue where the College submitted the direct lending disbursements via COD; however, they were rejected by COD due to a mismatch in the loan origination fee, as the loans were prepared using the loan origination fee effective prior to October 1, 2020, but reported to COD after October 1, 2020. This issue impacted several compliance requirements. During our testwork over Federal Direct Lending Reporting, we noted that for 7 of the 40 students selected, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations as a result of the loan origination fee issue. For these submissions, we noted that the submission dates ranged from 57 to 96 days, after the loans were reprocessed to update the loan origination fee amount. Based on the College?s analysis, the loan origination fee issue impacted 98 students, which resulted in the disbursement data for 98 students totaling $351,879 in loans not being reported to the COD website within the 15-day timeframe.
? Develop and document a more robust quality assurance program for Direct Loans. ? Conduct assessments of progress using COD reports and FSA Direct Loan Assessments. ? Develop and document internal and external reconciliation procedures. ? Staff training and development to include clear assignment of responsibilities, cross-training and regular, ongoing performance review.
2020-001
It is our understanding that the College evaluates SAP on an annual basis following the Spring semester and any students who were found not meeting SAP are alerted of this and notified that their federal aid eligibility has been terminated and are informed of the appeal process. For students that did not meet the SAP requirements, we noted the College did not maintain letters sent to students, notifying them of such and the appeal process. As a result, the College was not able to provide us with documentation to evidence that controls were in place and operating effectively to ensure that students were maintaining SAP. During our testwork we noted that all 40 students selected for testwork maintained SAP and were not required to be notified.
Show full finding ▾Hide full finding ▴It is our understanding that the College evaluates SAP on an annual basis following the Spring semester and any students who were found not meeting SAP are alerted of this and notified that their federal aid eligibility has been terminated and are informed of the appeal process. For students that did not meet the SAP requirements, we noted the College did not maintain letters sent to students, notifying them of such and the appeal process. As a result, the College was not able to provide us with documentation to evidence that controls were in place and operating effectively to ensure that students were maintaining SAP. During our testwork we noted that all 40 students selected for testwork maintained SAP and were not required to be notified.
For any student not meeting SAP at the end of the spring term, eligibility for federal student aid will be terminated and the student notified. The notice will provide the student with the specific reason for failure of SAP standards and the appeal process. A copy of this notification will be maintained. The report of students failing to meet federal SAP will be maintained as a cross-check to the communication to the student.
During our testwork we noted that for 2 of 40 students selected for testwork, had 2 loans each where disbursement notifications were sent more than 30 days after the students accounts were credited with the loans.
Show full finding ▾Hide full finding ▴During our testwork we noted that for 2 of 40 students selected for testwork, had 2 loans each where disbursement notifications were sent more than 30 days after the students accounts were credited with the loans.
An automated process runs weekly. Staff retrieve the report and send letters to students. This responsibility has been assigned to a staff member with the expectation that the report will be retrieved and reviewed weekly. SFS is exploring a process improvement by saving the letter as a PDF in one place in addition to imaging the letters directly into the student record. Further staff training and development, including cross-training, is planned.
2020-004
During our testwork we noted the following: ? The method used by the College to distribute Emergency Financial Aid Grants to students under the CARES Act (HEERF I) was not consistent with the method posted on the College?s website. ? The College did not accurately report the number of students eligible to receive and who did receive Emergency Financial Aid Grants to Students under the CRRSAA Act (HEERFII). ? The College did not maintain documentation to support when the Quarterly Public Reporting for Student Aid Portion under the CARES Act (HEERF I) was posted to their website for the quarter ending September 30, 2020 and therefore we were not able to ensure the reporting was timely.
Show full finding ▾Hide full finding ▴During our testwork we noted the following: ? The method used by the College to distribute Emergency Financial Aid Grants to students under the CARES Act (HEERF I) was not consistent with the method posted on the College?s website. ? The College did not accurately report the number of students eligible to receive and who did receive Emergency Financial Aid Grants to Students under the CRRSAA Act (HEERFII). ? The College did not maintain documentation to support when the Quarterly Public Reporting for Student Aid Portion under the CARES Act (HEERF I) was posted to their website for the quarter ending September 30, 2020 and therefore we were not able to ensure the reporting was timely.
Enhance internal controls: ? Reporting requirements will be documented by the designated reporting representative (currently the Director for Sponsored Programs and Foundation Relations). ? The units (i.e., SFS, Finance, IR) provide data to the designated reporting representative at the College. ? The designated reporting representative will review and draft the quarterly and annual reports for both student and institutional funds. ? Prior to submission, all entities providing data will be asked to review and confirm the data for their respective areas. ? The designated representative will certify the accuracy of the reporting. ? Any updates to website reporting will be dated and noted as such.
FAC accepted this audit on May 13, 2021 — management decision was due November 13, 2021.
During our testwork, we identified an issue where the College submitted the direct lending disbursements via COD; however, they were rejected by COD due to a mismatch in the loan origination fee, as the loans were prepared using the loan origination fee effective prior to October 1, 2019, but reported to COD after October 1, 2019. This issue impacted several compliance requirements. Reporting: During our testwork over Federal Direct Lending Reporting, we noted the following: ? For 10 of the 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations as a result of the loan origination fee issue. For these submissions, we noted that the submission dates ranged from 50 to 105 days, after the loans were reprocessed to update the loan origination fee amount. Based on the College?s analysis, the loan origination fee issue impacted 114 students, which resulted in the disbursement data for 114 students not being reported to the COD website within the 15-day timeframe. ? For 2 of the 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by federal regulations as a result of the loan origination fee issue. For these 2 students the loans were not reprocessed, but rather the Federal aid was replaced with institutional aid. Based on the College?s analysis, of the 114 students impacted by the loan origination fee issue, 3 students (2 of which were included in our testwork) did not have their loans reprocessed, but rather the Federal aid was replaced with institutional aid. ? For 3 of the 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations, which were not related to the loan origination fee issue. For these submissions, we noted that the submission dates ranged from 18 to 72 days. During our testwork over Pell Reporting, we noted that for 1 of 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations. We noted that the submission date was 337 days after the funds were disbursed to the student. Borrower Data Reconciliation (Direct Loan): During our testwork over the SAS reconciliation, we noted that the two monthly reconciliations that were selected for testwork were not appropriately completed or reviewed.
Show full finding ▾Hide full finding ▴During our testwork, we identified an issue where the College submitted the direct lending disbursements via COD; however, they were rejected by COD due to a mismatch in the loan origination fee, as the loans were prepared using the loan origination fee effective prior to October 1, 2019, but reported to COD after October 1, 2019. This issue impacted several compliance requirements. Reporting: During our testwork over Federal Direct Lending Reporting, we noted the following: ? For 10 of the 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations as a result of the loan origination fee issue. For these submissions, we noted that the submission dates ranged from 50 to 105 days, after the loans were reprocessed to update the loan origination fee amount. Based on the College?s analysis, the loan origination fee issue impacted 114 students, which resulted in the disbursement data for 114 students not being reported to the COD website within the 15-day timeframe. ? For 2 of the 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by federal regulations as a result of the loan origination fee issue. For these 2 students the loans were not reprocessed, but rather the Federal aid was replaced with institutional aid. Based on the College?s analysis, of the 114 students impacted by the loan origination fee issue, 3 students (2 of which were included in our testwork) did not have their loans reprocessed, but rather the Federal aid was replaced with institutional aid. ? For 3 of the 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations, which were not related to the loan origination fee issue. For these submissions, we noted that the submission dates ranged from 18 to 72 days. During our testwork over Pell Reporting, we noted that for 1 of 40 students selected for testwork, the required disbursement data was not reported to the COD website within the 15-day timeframe as required by Federal regulations. We noted that the submission date was 337 days after the funds were disbursed to the student. Borrower Data Reconciliation (Direct Loan): During our testwork over the SAS reconciliation, we noted that the two monthly reconciliations that were selected for testwork were not appropriately completed or reviewed.
Finding Number: 2020-001 Program Information: Student Financial Assistance Cluster, Federal Pell Grant Program and Federal Direct Student Loans CFDA Numbers: 84.063, 84.268 Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2019 ? June 30, 2020 Responsible Individual: Daniel Couture, Interim Director of Student Financial Services Contact information: dcouture@smcvt.edu 802.654.3243 Corrective Action Plan: ? The origination fee change will be set up correctly in Colleague, and multiple staff will be trained in this setup ? Direct Loan variances and reject reports generated by Colleague (ERP system) will be reviewed on a weekly basis and inaccuracies will be resolved timely ? The Operations Specialist will be trained in the reconciliation process in order to act as a reviewer/control for the Director ? G5 drawdowns will only occur only when Finance and SFS have consulted with each other, post-reconciliation, and concur on the reconciled amount to draw. Status of Correction Action: Complete
During our testwork, we noted 3 instances where amounts reported in the FISAP related to Federal Work Study did not agree to supporting documentation. In addition, we noted that some mathematical inaccuracies in the submitted FISAP.
Show full finding ▾Hide full finding ▴During our testwork, we noted 3 instances where amounts reported in the FISAP related to Federal Work Study did not agree to supporting documentation. In addition, we noted that some mathematical inaccuracies in the submitted FISAP.
Finding Number: 2020-002 Program Information: Student Financial Assistance Cluster, Federal Work-Study Program CFDA Number: 84.033 Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2019 ? June 30, 2020 Responsible Individual: Daniel Couture, Interim Director of Student Financial Services Contact information: dcouture@smcvt.edu 802.654.3243 Corrective Action Plan: The Director of SFS will coordinate with Finance to confirm the data being submitted on the FISAP is fully reconciled and agreed upon, before the final submission. Status of Correction Action: Complete
During our testwork we noted that for 1 of 40 students selected for testwork, funds were disbursed to the students account prior to the College obtaining a signed promissory note.
Show full finding ▾Hide full finding ▴During our testwork we noted that for 1 of 40 students selected for testwork, funds were disbursed to the students account prior to the College obtaining a signed promissory note.
Finding Number: 2020-003 Program: Information: Student Financial Assistance Cluster, Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2019 ? June 30, 2020 Responsible Individual: Daniel Couture, Interim Director of Student Financial Services Contact information: dcouture@smcvt.edu 802.654.3243 Corrective Action Plan: Functionality within Colleague will be implemented to require both the MPN and Entrance Counseling to be completed prior to loan disbursement. Staff will be trained on this process/control. Status of Correction Action: Complete
During our testwork we noted that for 2 of 40 students selected for testwork, the dates of the disbursement notifications did not appear to be accurate, as they were dated September 25, 2018, and the funds were disbursed to the student?s accounts in September 2019. As such, we were unable to verify that the students were notified of their loan disbursements within the required timeframe.
Show full finding ▾Hide full finding ▴During our testwork we noted that for 2 of 40 students selected for testwork, the dates of the disbursement notifications did not appear to be accurate, as they were dated September 25, 2018, and the funds were disbursed to the student?s accounts in September 2019. As such, we were unable to verify that the students were notified of their loan disbursements within the required timeframe.
Finding Number: 2020-004 Program Information: Student Financial Assistance Cluster, Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2019 ? June 30, 2020 Responsible Individual: Daniel Couture, Interim Director of Student Financial Services Contact information: dcouture@smcvt.edu 802.654.3243 Corrective Action Plan: An automated function from our report writing tool, Informer, creates a list of students to be notified with the appropriate ?Loan Disclosure.? Copies of these loan disclosures will be saved in our imaging system. The original date of the disclosure will be saved on the PDF copy of the disclosure. SFS transitioned to a new imaging system in the Fall of 2020. Documents will be saved in the same manner to this imaging system. Status of Correction Action: Complete
During our testwork we noted that for 1 of 60 students selected, the change in enrollment information and ?Program Level? was not successfully transmitted to NSLDS.
Show full finding ▾Hide full finding ▴During our testwork we noted that for 1 of 60 students selected, the change in enrollment information and ?Program Level? was not successfully transmitted to NSLDS.
Finding Number: 2020-005 Program Information: Student Financial Assistance Cluster, Federal Pell Grant Program and Federal Direct Student Loans CFDA Numbers: 84.063, 84.268 Federal Agency: U.S. Department of Education Federal Award Year: July 1, 2019 ? June 30, 2020 Responsible Individual: Marnie Owen, Registrar Contact Information: Mowen@smcvt.edu 802.654.2573 Corrective Action Plan: Registrar?s Office staff will attend workshops offered by the National Student Clearinghouse on best practices for follow up and resolution of rejected records so that rejects will be fully submitted, and subsequently transmitted to NSLDS. Status of Correction Action: Complete
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