College of Our Lady of the Elms

2024–002: Reporting – Significant Deficiency Federal Agency: U.S. Department of Education Federal Program Name: Fund for the Improvement of Postsecondary Education Assistance Listing Number: 84.116Z Federal Award Identification Number and Year: N/A; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Pass-Through Agency: N/A Pass-Through Numbers: N/A Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: All recipients of a multi-year discretionary award must submit an annual Grant Performance Report (34 CFR § 75.118). The annual performance report shall provide the most current performance and financial expenditure information that is sufficient to meet the reporting requirements of 2 CFR § 200.328, 200.329, and 34 CFR § 75.720. Condition/Context: During testing it was noted that the College did not submit the required annual report. Questioned costs: None Cause: The College does not have a control in place to ensure reporting requirements are met. Effect: Non-compliance with reporting requirements. Repeat Finding: No Recommendation: We recommend the College should establish a policy that provides the guidance required to comply and address regulatory reporting requirements. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: Various Award Period: July 1, 2020 to June 30, 2021 2021-002 Type of Finding: Other Matters and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Department of Education regulations, changes in the enrollment status of federal loan recipients must be reported to NSLDS within 30 days, unless the school has a scheduled batch submission within 60 days and will report the change at that time. Condition: During our testing, we noted 4 out of 40 students who were not reported timely to NSLDS. Additionally, we noted 7 out of 40 students whose enrollment status was not reported correctly. Questioned Costs: None. Context: The College was not able to comply with the requirement to report to NSLDS within the required time frame. Cause: Four students withdrawals were not reported to NSLDS within the required timeframe, and seven student enrollment status changes were not submitted correctly. Effect: As NSLDS reporting dates impact student repayment and interest charges, it is important that student status changes are reported timely and properly to NSLDS. Repeat Finding: No Recommendation: The College should review its policies and procedures surrounding its reporting of enrollment status changes to NSLDS and implement a review process to ensure that errors are properly followed up on and manual adjustments are reviewed. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: Various Award Period: July 1, 2020 to June 30, 2021 2021-003 Type of Finding: Other Matters and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Student Status Confirmation Reports (SSCRs) submitted to the National Student Loan Data System (NSLDS) by the National Student Clearinghouse to correct enrollment reporting errors were not accepted timely. Condition: Failure to comply with the requirement to have error response files filed and accepted within the 10-day times frame. Questioned Costs: None. Context: During our testing, we noted instances where error reports were not corrected within the required 10-day timeframe. Cause: Error batches returned by NSLDS to NSC (the College?s servicer) were not communicated to the school. Effect: Failure to comply with timely enrollment reporting error correction requirements, and failure to correct misreported information to NSLDS. Repeat Finding: No Recommendation: We recommend the College implement additional controls to ensure timely reporting, processing, and tracking of SSCR error files, error file responses, and file receipt acknowledgments for data submitted to NSLDS by the Clearinghouse. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.038 ? Federal Perkins Loan Program Award Period: July 1, 2020 to June 30, 2021 2021-004 Type of Finding: Other Matters and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires the University to retain 1.) original or true and exact copies of promissory and master promissory notes (MPN), 2.) repayment records, 3.) cancellation and deferment request for each Perkins loan made. Condition: During our testing of borrowers with open loans, we noted the College did not have original or true copies of master promissory notes for 2 of the 40 students tested. Questioned Costs: None. Context: During our testing of borrowers with open loans, we noted the College was not able to locate two original or true copies of promissory or master promissory notes for older loans as detailed in this finding. Cause: While the College has processes and controls in place to maintain Perkins loan promissory and master promissory notes, due to the age of some of the loans subject to testing, the controls around the maintenance of those forms did not operate effectively on a few occasions. Effect: The College may have to purchase students outstanding loans as a result of not retaining necessary information needed to assign them. Repeat Finding: No Recommendation: The College has liquidated from the Perkins program and therefore no formal update of internal controls would be necessary; however, the College should understand the ramifications of not having such documentation and take corrective measures if required. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

Sponsor Award CFDA Federal Pell Grant Program 84.063 Criteria Students eligible for Pell who are considered full time students are entitled to 100% of their award amount. Condition A student selected for the Pell Loan Testing only received 75% of their awarded Pell amount for the Fall 2019 semester because they only had 9 credits scheduled. This student?s transcript for the Fall 2019 showed 12 credits, therefore the student should have received the full amount. Cause Within the Fall semester, there are two Fall terms. The student had 9 credits in Fall term 1 and 3 credits in Fall term 2 for a total of 12 credits. The Ellucian financial aid system did not recognize that the Fall 1 term and the Fall 2 term are within the Fall semester, and therefore awarded the student as if they were a part time student. Effect The student was entitled to an additional $774 in aid. Questioned costs There are no questioned costs as a check was written to the student for the difference between amount received and amount that should have been provided. Consequences of audit finding Management reviewed all students that were Pell eligible and who had credits in both Fall Semester 1 and 2 and noted that this was an isolated incident affecting only one student. Additionally, the College no longer has two fall semesters. Repeat finding This is not a repeat finding from the year ended June 30, 2019. Recommendation We recommend that if the College decides to run two fall or spring semesters, it must ensure that all credits are captured in their software for students that attend classes in both semesters. Views of responsible officials and planned corrective actions Management is no longer running two fall semesters and therefore there will be no need to combine credits from two fall semesters to calculate Pell award amounts.

Sponsor Award CFDA Federal Direct Student Loans 84.268 Federal Pell Grant Program 84.063 Criteria Whenever an institution disburses Title IV funds by crediting a student?s account and the total amount of all Title IV program funds credited exceeds the amount assessed to the student for allowable charges (tuition and fees, room and board, and other authorized charges), the institution must pay the resulting credit balance directly to the student or parent as soon as possible but no later than 14 days after the balance occurred if the credit balance occurred after the first day of class or 14 days after the first day of class if the credit balance occurred on or before the first day of class (34 CFR Section 668.164(h)). Condition Of the forty-three students selected for credit balance testing, we noted two students whose credit balances were not paid within 14 days after the credit balance occurred who did not have a form on file to authorize the funds to remain on account. Cause The two students had their credit balance paid 31 days (17 days late) and 16 days (2 days late), respectively, after the credit balance occurred. The College was unable to locate documentation as to why the balances were not paid out to the students timely. Effect Although late, credit balances were returned to both students. Questioned costs There were no questioned costs as all credit balances were paid to the students, however two were late. Federal funds that remained on the student?s account in excess of allowable charges less any amounts paid to the student within 14 days totaled $2,931. One student received payment 17 days late and the other student received payment 2 days late. Consequences of audit finding We selected forty-three students for testing with total Federal financial aid of $756,051, of which thirty had credit balances on account and two Federal credit balances totaling $2,931 were noted as late. Based on the amounts tested in relation to total Federal financial aid, projected late payments for the entire population related to this finding could total $58,112. See Schedule of Findings and Questioned Costs for chart/table. Repeat finding This is not a repeat finding from the year ended June 30, 2018. Recommendation We recommend that the College continue to improve this process to ensure that all credit balances are returned to the student within the required timeframe and that the appropriate authorization forms are obtained and kept on file. The College should consider notification to the student at the time the credit balance arises that their credit balance check is available for pick up in the Business Office. In addition, for off campus students, the College should estimate the tuition and fees expected to be applied and pay out any expected credit balance. The student should be notified of their credit balance on their account as a result of the timing of application of their off campus tuition and fees, what the expected charges will be, and any payment available at that time. They should also state that payment of any credit balance resulting after actual charges are applied will be available for pick up in the Business Office. Views of responsible officials and planned corrective actions Management continues to improve the credit balance review process to allow it to identify and refund federal credit balances within the 14 day requirement. Procedures have now been formally documented and maintained. The secondary review by the Controller will include the full report with notations by student accounts.

Sponsor Award CFDA Federal Pell Grant Program 84.063 Criteria Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew (34 CFR section 668.173(b)). Condition We noted that for one of the six students tested, a refund was returned 121 days after the student withdrew. Cause The finding was a result of the Financial Aid Office not being notified in a timely manner by other departments when a change in enrollment status occurred which resulted in the refund calculation being performed past the 45 day requirement. Effect All refunds were returned to the Department of Education. Questioned costs There were no questioned costs, as all required refunds were returned to the Department of Education, however $761 was late. This was calculated as the amount of student financial aid less amounts earned using the Return of Title IV Funds worksheet. Consequences of audit finding We tested six refunds totaling $24,275 and the Pell component of one refund in the amount of $761 was noted as late. Based on the amounts tested in relation to total refunds, projected late payments related to this finding could total $1,335. Sample Population from which the sample was drawn Sample Description OPEID Students Having Pell Refund (#) Pell Refunded ($) Students Receiving Pell Total Refunded Return of Title IV Funds 00214000 6 $24,275 16 $42,491 Finding Number Student Identifier OPEID Pell Disbursed Pell Under-payment Pell Over- Payment 2019-002 Student 3 00214000 $4,571 - $761 Recommendation We recommend that the College increase communication between the Registrar?s Office and Financial Aid Office to ensure enrollment changes are identified as soon as possible. We also recommend that the College utilize their listing of student withdrawals with financial aid as a way of monitoring whether refund calculations are necessary, the due date of the refund and whether the calculation and refund have been completed. This will assist in ensuring that refunds are made within the required timeframe. Views of responsible officials and planned corrective actions Management will continue working with the Registrar's Office, program coordinators, and faculty to assure timely notification to all offices when a student has a change in their enrollment status.

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