Goddard College CorporationHigher Education

Condition: As of the audit period ending June 30, 2023, the College was found to be in non-compliance with the Uniform Guidance (2 CFR 200, Subpart E, Section 200.90). A student (1 of 40 tested) failed to maintain satisfactory academic progress (SAP), was not provided a notice of a probationary period. It was noted that this student was also an employee of the College and proper segregation of duties did not exist. Context: The College has established SAP standards, including credit completion requirements, as outlined in its published financial aid policies. These standards are in accordance with the Uniform Guidance requirements for administering federal financial aid. In addition, the employee in the registrar's office was also the student in question. Cause: The student in question is a member of the registrar’s office, causing a potential conflict of interest or lack of segregation of duties. Effect or Potential Effect: Student did not receive notice of the probationary period. Questioned Costs: None noted. Recommendations: The College should ensure those in the registrars office are not able to award themselves credit. Implement Automated Alerts: Explore the implementation of automated systems to generate alerts when a student's academic progress deviates from the SAP standards, facilitating prompt intervention. Training for Financial Aid Staff: Provide additional training for financial aid staff to ensure a comprehensive understanding of SAP regulations and the importance of strict adherence. Segregation of Duties: The College should establish adequate segregation of duties to ensure a member of the registrar’s office is not also the individual responsible to review their own SAP status.

Criteria: Formally documented internal control procedures ensure schedules are ready for a Single Audit on a timely basis. This ensures submission of the Single Audit report as required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition: The College failed to submit the Single Audit report to the Federal Audit Clearinghouse by the required deadline. Questioned Costs: None noted. Context: The College was required to submit the June 30, 2022, Single Audit report to the Federal Audit Clearinghouse within nine months of the College’s year-end. The College did not submit this report in the required period. Effect: The lack of formal process to provide timely audit support could result in the late submission of the Single Audit report. Cause: The College did not submit the audit in a timely manner. Recommendation: The College should develop formally documented internal control procedures to outline a process to review grant agreements for audit requirements. Additionally, the College should develop formally documented internal control procedures that allow sufficient time to properly conduct a Single Audit. View of Responsible Officials and Planned Corrective Actions: See accompanying Corrective Action Plan as prepared by management.

2022-002 Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The change in student status for 15 of 17 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. A statistical sample was not used. Cause: The College failed to follow its procedures for reporting student status changes. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Questioned Costs: None Recommendation: The College should review its policy on enrollment reporting to NSLDS to ensure that all enrollment status changes are updated accurately and reported within the required timeframe. View of Responsible Officials and Planned Corrective Actions: See accompanying Corrective Action Plan as prepared by management.

Finding 2021-001 Award Name: Student Financial Aid ? Federal Direct Loans CFDA Number: 84.268 Condition Found: During testing, in our sample of twenty-one disbursements, it was found that two disbursements did not have the appropriate notifications Criteria: Per 34 CFR Section 668.165(2), the school must notify the student and parents within 30 days of any disbursements made onto the student's account for loan proceeds. Context: Because of significant IT issues with the software in FY20, the College had to do notifications manually. Because of the manual process, a very small amount of notifications were missed. Effects: Some students did not get the appropriate notification, and thus did not automatically know that loans were being posted to their account so that they could cancel, if requested. Questioned Costs: N/A Cause of Non-Compliance: The manual process coupled with the lack of staffing caused some of the loan notifications to be missed. Recommendation for Corrective Action: We recommend that the College re-implement their procedures to send out the notifications on a timely basis. The College has done so by working towards implementing a new software program to once again automate the loan notification process to help eliminate the missing notifications.

Finding 2021-002 Award Name: Student Financial Assistance ? Federal Direct Loans CFDA Number: 84.268 Condition Found: The College could not provide evidence that they had timely reconciled their SAS reports on a monthly basis to their internal records. Criteria: Per Code 34 C.F.R Section 685.102(b), the school is required to reconcile the loans that they disburse to their internal records. Per the Direct Loans School Guide, it states more specifically that the reconciliation should reconcile the SAS reports received from COD to the G5 cash system and the cash should be tied out at the end of every month. Context: The finding in the prior year was issued in March. The College had already done the reconciliations as had been done previously, and did not have the reconciliations with the SAS report information. Effects: The College was able to provide evidence that they performed the May reconciliation with all of the required information but the earlier reconciliations in the year were done without all of the required information. Questioned Costs: N/A Cause of Non-Compliance: There was confusion among the staff on this requirement after the departure of a former key staff member who had performed the task in prior years. They were not aware of the missing information until the audit disclosed it in March of 2021. Recommendation for Corrective Action: We recommend that the College print the reconciliations and initial and date them upon performance and review to provide evidence of timely reconciliations. They were able to provide evidence they did this corrective action for the May reconciliation but not the earlier reconciliations. Reconciliations going forward to have the appropriate information.

Finding 2020-001 Award Name: Student Financial Aid ? Federal Direct Loans CFDA Number: 84.268 Condition Found: During testing, it was found that all students during the Fall semester did not get notifications when federal loans were posted to their accounts. Criteria: Per 34 CFR Section 668.165(2), the school must notify the student and parents within 30 days of any disbursements made onto the student's account for loan proceeds. Context: Because of significant staffing shortages in the Business Office as well as the IT Office, the system was not being checked to ensure that loan notifications were going out automatically when funds hit students? accounts in the Spring of 2019. This issue was not discovered until the Uniform Guidance audit was conducted in November of 2019. The correction was made but not until after the entire Fall semester was completed. Effects: All students in the Fall of 2019 did not get the appropriate notification and thus did not automatically know that loans were being posted to their account so that they could cancel if requested. Questioned Costs: N/A Cause of Non-Compliance: The sudden departure of several staff caused a manpower shortage which did not allow the College to ensure the notifications were being sent. Recommendation for Corrective Action: We recommend that the College re-implement their procedures to send out the notifications on a timely basis. They have since done so and we can see evidence of such in the Spring semester of 2020.

Finding 2020-002 Award Name: Student Financial Assistance ? Federal Direct Loans CFDA Number: 84.268 Condition Found: The College could not provide evidence that they had timely reconciled their SAS reports on a monthly basis. Criteria: Per Code 34 C.F.R Section 685.102(b), the school is required to reconcile the loans that they disburse to their internal records. Per the Direct Loans School Guide, it states more specifically that the reconciliation should reconcile the SAS reports received from COD to the G5 cash system and the cash should be tied out at the end of every month. Context: A review of the reconciliations provided did not contain evidence of the timely preparation of the reconciliations. Effects: The College lacks sufficient documentation to show the reconciliations were prepared on a timely basis. There could be funds that are not properly disbursed in COD or in the College?s internal AR software if the reconciliations are not prepared timely. Questioned Costs: N/A Cause of Non-Compliance: There was confusion among the staff on this requirement after the departure of a former key staff member who had performed the task in prior years. Recommendation for Corrective Action: We recommend that the College print the reconciliations and initial and date them upon performance and review to provide evidence of timely reconciliations

Finding 2019-001 Award Name: Student Financial Aid ? Federal Direct Loans CFDA Number: 84.268 Condition Found: During testing, it was found that, in March, the College did two drawdowns of federal funds and did not apply the amounts to student balances or return to the Department by the end of the third business day. Because of turnover in the Business Office, the College did not follow their internal control procedure of tying the drawdown to a roster of disbursed aid and check COD to ensure that they were only drawing down loans that were posted. Criteria: Per 34 CFR 668.166(a)(1), Title IV Funds are to be disbursed to students by the end of the third day following receipt from the funds. Context: Two employees with significant experience in the federal funds process gave their notice at the same time. Because of the sudden departure of these two key staff, there was no proper training over the internal control procedures over cash management to ensure this type of noncompliance did not occur. Effects: Excess cash was swept into the College?s Sweep account for a month before they were properly returned to the Department of Education. While in the Sweep account, the funds earned interest. Questioned Costs: $582 Cause of Non-Compliance: The sudden departure of two key staff and lack of training caused the non-compliance. Recommendation for Corrective Action: We recommend that the College re-implement their internal controls to tie drawdowns to rosters and check the COD disbursed aid prior to drawing down funds. The College had already corrected and re-implemented this control prior to our arrival to audit.

Finding 2019-002 Award Name: Student Financial Aid ? Federal Direct Loans CFDA Number: 84.268 Condition Found: During testing, it was found that there were several students during the spring semester that did not get notifications when federal loans were posted to their accounts. Criteria: Per 34 CFR Section 668.165(2), the school must notify the student and parents within 30 days of any disbursements made onto the student's account for loan proceeds. Context: Because of significant staffing shortages in the Business Office as well as the IT Office, the system was not being checked to ensure that loan notifications were going out automatically when funds hit students? accounts. Effects: Several students did not get the appropriate notification and thus did not automatically know that loans were being posted to their account so that they could cancel if requested. Questioned Costs: N/A Cause of Non-Compliance: The sudden departure of several staff caused a manpower shortage which did not allow the College to ensure the notifications were being sent. Recommendation for Corrective Action: We recommend that the College re-implement their procedures to send out the notifications on a timely basis.

Finding 2019-003 Award Name: Student Financial Aid ? Federal Direct Loans CFDA Number: 84.268 Condition Found: During testing, it was found that there was one student whose spring loan did not get returned timely due to the issue with overdrawn federal funds. Criteria: Per 34 CFR Section 668.22(j), the school must return funds for which it is responsible as soon as possible, but no later than 45 days after the date of the school?s determination that the student withdrew. Context: Because of significant staffing shortages in the Business Office, the school overdrew their federal funds during the 45 day period and were unaware. They normally leave additional federal funds available to draw on to cover refunds but did not in this year. Effects: One student?s refund was returned in 48 days rather than 45. 100% of the refunds for the semester that the College was overdrawn were selected and tested. Only one refund was late because of this issue. Questioned Costs: N/A Cause of Non-Compliance: The sudden departure of two key staff and lack of training caused the non-compliance. Recommendation for Corrective Action: We recommend that the College re-implement their internal controls to tie drawdowns to rosters and check the COD disbursed aid prior to drawing down funds. The College had already corrected and re-implemented this control prior to our arrival to audit.