EIN: 042134818
UEI: NSBEDCSU4CR6
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 2025. 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, 2025 (329 days ago).
What is a management decision? →During the year ended June 30 2024, the College failed the debt service coverage ratio covenant included in its agreement with its lender, which is a triggering event that should have been reported to the ED within twenty-one days of occurrence of the event. Context: ED requirements for reporting triggering events. The triggering event occurred on June 30, 2024 and the College failed to communicate the event to the ED. Cause: Lack of procedures in place to identify triggering events that require reporting to the ED. Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding. Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner. Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038 Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within twenty-one days of the event. Condition: During the year ended June 30 2024, the College failed the debt service coverage ratio covenant included in its agreement with its lender, which is a triggering event that should have been reported to the ED within twenty-one days of occurrence of the event. Context: ED requirements for reporting triggering events. The triggering event occurred on June 30, 2024 and the College failed to communicate the event to the ED. Cause: Lack of procedures in place to identify triggering events that require reporting to the ED. Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding. Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner. Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
We recommend that the College implement procedures to ensure triggering events are identified and reported to ED in a timely manner. There was confusion as to what needed to be reported due to the fact that one default notice was issued in December 2023 for the FY23 covenant and the bank delayed the amendment knowing that FY24 would be covered by the amendment the same default notice. Reporting of the amendment took place in February of 2025, and a reporting will be made as soon as possible, if it is deemed necessary for FY25. As of right now the College is expeceted to meet its covenants for FY26. VP of Administration and Finance will reach out within 21 days if that is not the case.
2023-002
Out of 40 outstanding Perkins loans selected for testing, the College was unable to provide the original promissory note for one loan. Questioned Costs: None Effect: Failure to retain or safeguard original documentation could result in missing supporting documentation for outstanding loans. Cause: Employee turnover in the past was an underlying cause. Recommendation: We recommend the college evaluate their procedures for maintaining original documentation and ensure there is a control over maintaining prior documentation over time. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions were made.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster – Federal Perkins Loan Program: ALN 84.038 Criteria: In accordance with Department of Education requirements, institutions must retain original or true and exact copies of promissory and master promissory notes (MPN) for each Perkins Program loan made. Institutions are required to keep original paper promissory notes or original paper master promissory notes and repayment schedules in a locked, fireproof container. Such documents must be kept until the loans are satisfied. Condition: Out of 40 outstanding Perkins loans selected for testing, the College was unable to provide the original promissory note for one loan. Questioned Costs: None Effect: Failure to retain or safeguard original documentation could result in missing supporting documentation for outstanding loans. Cause: Employee turnover in the past was an underlying cause. Recommendation: We recommend the college evaluate their procedures for maintaining original documentation and ensure there is a control over maintaining prior documentation over time. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions were made.
The College will evaluate their procedures for maintaining original documentation and ensure there is control over maintaining prior documentation over time. The college underwent an internal review of all Perkins promissory notes and plans to purchase back the loan in the event the promissory notes cannot be found. Rani Arsenault in the Business Office will identify missing promissory notes in FY25.
FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.
The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event. Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023. Cause: Lack of procedures in place to identify triggering events that require reporting to the ED. Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding. Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner. Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007, Federal Perkins Loan Program: ALN 84.038Criteria: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurrence of specific events, known as triggering events, to them within ten days of the event. Condition: The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College’s Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurrence of the event. Context: ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023. Cause: Lack of procedures in place to identify triggering events that require reporting to the ED. Effect: Failure to report triggering events could result in the College being required to obtain a letter of credit or other surety or financial protection or result in the loss of the College’s eligibility to participate in Title IV funding. Recommendation: We recommend that the College implement procedures to ensure triggering events are identified and reported to the ED in a timely manner. Views of responsible officials and planned corrective actions: Management agrees with the finding, and corrective measures are being made.
Finding: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurance of specific events, known as triggering events, to them within ten days of the event. The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College's Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurance of the event. ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023. Corrective Action Plan. The College has implemented procedures to ensure triggering events are identified and reported to the ED in a timely mannger. The Financial Aid Director: Erin Hanlon or VP of Administration and Finance: William McDonald is responsible for communicating triggering events once identified.
There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022 and controls in place did not identify the excess cash. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested during the June 30, 2022 audit. The sample was not intended to be, and was not, a statistically valid sample. Our testing during the June 30, 2023 audit did not identify any amount of excess cash remaining in the College’s account after September 20, 2022. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions were made.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution’s prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022 and controls in place did not identify the excess cash. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested during the June 30, 2022 audit. The sample was not intended to be, and was not, a statistically valid sample. Our testing during the June 30, 2023 audit did not identify any amount of excess cash remaining in the College’s account after September 20, 2022. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions were made.
Finding: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated witin the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediatley in its account within the seven-day tolerence period. There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022 and controls in place did not identify the excess cash. The maximum daily excess balance during this time period was $51,701. Corrective Action Taken. The return of excess cash took place on 9/30/2022. Because the excess cash was identified and returned in this award year and pertained to the previous award year it is identified as a repeat finding. Internal control to regularly monitor and reconcile to drawdowns to ensure applicable requirements are met have been implemented and managed by Associate Controller Megan Donovan.
2022-005
The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change. Questioned Costs: None. Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster – Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity 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 statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 5 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The students’ status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred between 70 and 161 days for the five students from the date of status change. Questioned Costs: None. Prevalence: Identified in 5 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Cause: The College’s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity 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 statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: Management, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enroll,ent information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally a review of the submitted enrollment data to the NSLDS be performed to ensure current student status information and status is properly reflected. Enrollment reporting corrections will be corrected by April 30, 2024. The following outlines of steps to be taken will be implemented immediately: 1. Ensure that multiple people are trained to report to NSC. a. This would mean at least once a semester having multiple peoples (at least two) involved in not only the reporting b. Also, others should be trained and aware of the follow-up correction process. 2. Reporting to NSC on a more frequent basis (twice a month). a. Right now, we report once a month at the end of each month. b. As long as students are reported within 60 days, they are within reported guidelines, so this has typically been ok. c. Reporting twice a month ensures any changes in enrollment are caught early. 3. Working with other departments (registrars/admissions/etc.) to find the common errors in the reporting and find ways to make sure these errors do not occur. a. Meeting at least once a semester to review where the most common/most errors occurred. b. Formulate processes to make sure these errors don't slow down reporting times.
2022-004
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
As it related to the institutional portion of HEERF, the College inaccurately reported the quarterly amount drawn from the G5 system and reported amounts in the wrong category (misclassified). Questioned Costs: None. Prevalence: Identified in 2 out of 4 institutional quarterly reports tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The College was not in compliance with reporting requirements for HEERF as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures have been taken.
Show full finding ▾Hide full finding ▴Finding No. 2022-002 ? Higher Education Emergency Relief Funds Reporting (Repeat Finding ? 2021-001) Federal Agency: U.S. Department of Education (DOE) Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The College is required to publicly report both timely and accurately on its website aggregate amounts expended for Higher Education Emergency Relief Funds (HEERF) each quarterly reporting period from assistance listings 84.425F Institutional Portion and 84.425M Strengthening Institutions Program. The College must post the quarterly report form no later than 10 days after the end of each calendar quarter publicly on the College?s website on the same page the reports of the College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Additionally, the amounts reported in the quarterly reports must reconcile to the underlying documentation to ensure accuracy. Condition: As it related to the institutional portion of HEERF, the College inaccurately reported the quarterly amount drawn from the G5 system and reported amounts in the wrong category (misclassified). Questioned Costs: None. Prevalence: Identified in 2 out of 4 institutional quarterly reports tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The College was not in compliance with reporting requirements for HEERF as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures have been taken.
Finding: No. 2022-002 Higher Education Emergency Relief Funds Reporting. Finding: Institutions that expended HEERF grant funds during the calendar quarter from January 1- March 30, 2021 are required to post the quarterly report that involved the expenditure of HEERF I CARES Act funds and HEERF II CRRSAA. The Department did not previously affirm this reporting requirement for HEERF II CRRSAA funds. As such, institutions may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. The specific errors were that the amount reported on the 12/31/2020 quarterly report was $38,750 but based on the drawdowns, no funds were drawn in this quarter and that $ 38,750 was drawn in February 2021 and was captured in the total reported on the 3/31/2021 quarterly report. The other issue is that on the 3/31/2021 and 6/30/2021, the amounts drawn for SIP should have been reported separately in the 18004(a)(2) column. Corrective Action Taken or Planned: The issue was the result of a misunderstanding of how drawdowns versus actual expenditures were reported. There were corrections made to the quarterly reports, however, the report in question was never updated on the website. The quarterly reports were corrected by the VP of Administration and Finance, William McDonald and posted to our website by the end of September 2022. according to the previous corrective action plans 06/30/2021. The issue arising is the 09/30/2021and 12/31/2021 reports for the fiscal year ending 06/30/2022 were wrong and corrected at the same time. The VP of Administration and Finance made the corrections to the quarterly report as of 09/30/2022. Corrections have been completed as of 09/30/2022.
2021-001
There was no evidence that direct outreach was performed during the fiscal year in which the remaining federal fundings under the award were expended. Questioned Costs: None. Prevalence: There was no evidence that direct outreach occurred as required by the program. Effect: Not complying with requirements outlined within applicable grant agreements could result in the DOE withholding payments to the College. Cause: This issue is a result of a lack of proper understanding of applicable requirements. Recommendation: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, we recommend that management implement a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Show full finding ▾Hide full finding ▴Finding No. 2022-003 ? Higher Education Emergency Relief Funds Earmarking Federal Agency: U.S. Department of Education Program: COVID-19 Education Stabilization Fund: ALN: 84.425 Criteria: The American Rescue Plan created a new requirement that a portion of the HEERF III institutional funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. Condition: There was no evidence that direct outreach was performed during the fiscal year in which the remaining federal fundings under the award were expended. Questioned Costs: None. Prevalence: There was no evidence that direct outreach occurred as required by the program. Effect: Not complying with requirements outlined within applicable grant agreements could result in the DOE withholding payments to the College. Cause: This issue is a result of a lack of proper understanding of applicable requirements. Recommendation: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, we recommend that management implement a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding: No. 2022-003 Higher Education Emergency Relief Funds Earmarking. Finding: The American Rescue Plan (ARP) created a new requirement that a portion of the HEERF III Institutional Funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. The College utilized direct emails to students, however, no evidence of direct outreach occurred as required by the program. Corrective Action Taken or Planned: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, management will have implemented a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Both the Financial Aid Director, Erin Hanlon and the VP of Administration and Finance, William McDonald will regularly monitor and manage changes to rules and regulations promulgated by the DOE effective immediately 3/29/2023.
The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Show full finding ▾Hide full finding ▴Finding No. 2022-004 ? Enrollment Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity 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 statues, regulations, and terms and conditions of the federal award. Condition: The College generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 2 students whose change in enrollment status was not timely and accurately transmitted to NSLDS. The College was notified of the students? enrollment status change from three-quarter time to ?withdrawn?. Accordingly, the students? status changes should have been transmitted as part of the roster file required to be reported within 60 days of the status change. However, in submitting enrollment information through rosters provided to the NSC, the status change occurred 72 days for one student and 74 days for the other student from the date of status change. Questioned Costs: None. Prevalence: Identified in 2 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Untimely submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Cause: The College?s internal control process did not operate consistently to ensure that all enrollment information, including status changes, were submitted timely to NSLDS. Recommendation: We recommend that the College review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Reporting Views of Management and Corrective Actions: Management agrees with the finding, and corrective measures are being made.
Finding: No. 2022-004 Enrollment Reporting Finding: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity 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 statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: The College, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally, a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Enrollment reporting corrections have been corrected as of 03/29/2023.
There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Show full finding ▾Hide full finding ▴Finding No. 2022-005 ? Cash Management Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN 84.268, Federal Pell Grant Program: ALN: 84.063, Federal Work-Study Program: ALN 84.033, Federal Supplemental Educational Opportunity Grants: ALN 84.007 Criteria: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time-period was $51,701. Questioned Costs: None Prevalence: Identified in 1 out of 15 disbursements tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: The DOE may require the institution to reimburse it for the costs the federal government incurred in providing that excess cash to the institution; and provide funds to the institution under the reimbursement payment method or heightened cash monitoring payment method (as described in CFR 668.162(c) and (d)). Cause: This issue is the result of improper controls surrounding drawdowns to ensure that they are expended or returned to the DOE within the required timeframe. Recommendation: We recommend management implement a control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Reporting Views of Management and Corrective Actions: Management agrees with the finding and corrective actions will be made.
Finding: No. 2022-005- Cash Management Finding: An excess cash balance tolerance is allowed if that balance is less than 1% of the institution's prior-year drawdowns and is eliminated within the next seven calendar days (34 CFR 668.166(a) and (b)). The institution must return immediately any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account within the seven-day tolerance period. Condition: There was one drawdown from the G5 during the year for federal direct loans in which the College was in an excess cash position starting on June 29, 2022, through September 20, 2022. The maximum daily excess cash balance during this time was $51,701. Corrective Action Taken or Planned: Management will review and follow internal control to regularly monitor disbursements and reconcile to drawdowns to ensure applicable requirements are met. Corrective action has been taken to return any amount of excess cash, as of 09/30/2022 completed by the VP of Administration and Finance, William McDonald.
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
The Quarterly Budget and Expenditure Reporting under CARES Act Sections 18004(a)(1) Institutional Portion, 18004(a)(2), and 18004(a)(3) report was inaccurately reported as the $66,063 in Section 18004(a)(2) funds expended in fiscal year 2021 were not reported in the correct columns as outlined in the form?s instructions. Additionally, 1 of the 4 quarterly reports did not reconcile to the underlying support by a difference of $38,750. Internal controls over reporting were not sufficient to prevent or detect the noncompliance from occurring. Context: See ?Condition? above. Effect: The College was not in compliance with reporting requirements for the Higher Education Emergency Relief Funds as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2021-001 Higher Education Emergency Relief Funds Reporting Criteria: The College is required to publicly report both timely and accurately on its website aggregate amounts expended for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period from assistance listings 84.425F Institutional Portion and 84.425M Strengthening Institutions Program. The College must post the quarterly report form no later than 10 days after the end of each calendar quarter publicly on the College?s website on the same page the reports of the College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. Additionally, the amounts reported in the quarterly public reports must reconcile to the underlying documentation to ensure accuracy. Condition: The Quarterly Budget and Expenditure Reporting under CARES Act Sections 18004(a)(1) Institutional Portion, 18004(a)(2), and 18004(a)(3) report was inaccurately reported as the $66,063 in Section 18004(a)(2) funds expended in fiscal year 2021 were not reported in the correct columns as outlined in the form?s instructions. Additionally, 1 of the 4 quarterly reports did not reconcile to the underlying support by a difference of $38,750. Internal controls over reporting were not sufficient to prevent or detect the noncompliance from occurring. Context: See ?Condition? above. Effect: The College was not in compliance with reporting requirements for the Higher Education Emergency Relief Funds as the amounts were not accurately reported. Cause: There was conflicting and/or unclear guidance available at various times during the fiscal year that led to some misunderstandings on how to report information accurately on the quarterly reporting forms. Additionally, review controls over the reconciliation of information reported to the underlying documentation did not operate effectively. Recommendation: We recommend that the College correct the quarterly reports on its website and ensure that review controls are adequately designed to ensure the accuracy of the amounts reported. Reporting Views of Management and Corrective Actions: Management agrees with the finding. See Corrective Action Plan.
CORRECTIVE ACTION PLAN June 30, 2021 Finding: Institutions that expended HEERF grant funds during the calendar quarter from January 1 - March 30, 2021 are required to post the quarterly report that involved the expenditure of HEERF I CARES Act funds and HEERF II CRRSAA. The Department did not previously affirm this reporting requirement for HEERF II CRRSAA funds. As such, institutions may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have not already done so. The specific errors were that the amount reported on the 12/31/2020 quarterly report was $38,750 but based on the drawdowns, no funds were drawn in this quarter and that$ 38,750 was actually drawn in February 2021 and was captured in the total reported on the 3/31/2021 quarterly report. The other issue is that on the 3/31/2021 and 6/30/2021,the amounts drawn for SIP should have been reported separately in the 18004(a)(2) column. Corrective Action Taken or Planned: The issue was the result of a misunderstanding of the how drawdowns versus actual expenditures were reported. There were corrections made to the quarterly reports, however, the report in question was never updated on the website. The quarterly reports will be reviewed and corrected by the VP of Administration and Finance and posted to our website by the end of September 2022.
FAC accepted this audit on December 21, 2016 — management decision was due June 21, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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