EIN: 131740448
UEI: NT8TUD8VBZC9
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 26, 2023. 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 May 26, 2024 (823 days ago).
What is a management decision? →The College relies upon flag reports generated by the College’s Banner system to verify and monitor the eligibility of students to receive Federal Student Financial Assistance awards. The Director of Financial Aid receives and reviews the students flagged with eligibility exceptions that need to be resolved before Federal Student Financial Assistance is disbursed. Based upon the review and resolution of eligibility flags, Federal Student Financial Assistance is disbursed, or the student is determined to be ineligible for Federal Student Financial Assistance. The Director of Financial Aid was unable to provide copies of exception reports, therefore we were unable to determine if controls over eligibility were in place and operating effectively. Status: Due to the closure of the College, the Banner system was shutdown with management losing access to electronic files in the system. Maintenance of proper financial records and student enrollment files in paper form were not kept by management nor was the data downloaded from Banner prior to the system being shutdown. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-002 Eligibility FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: The College relies upon flag reports generated by the College’s Banner system to verify and monitor the eligibility of students to receive Federal Student Financial Assistance awards. The Director of Financial Aid receives and reviews the students flagged with eligibility exceptions that need to be resolved before Federal Student Financial Assistance is disbursed. Based upon the review and resolution of eligibility flags, Federal Student Financial Assistance is disbursed, or the student is determined to be ineligible for Federal Student Financial Assistance. The Director of Financial Aid was unable to provide copies of exception reports, therefore we were unable to determine if controls over eligibility were in place and operating effectively. Status: Due to the closure of the College, the Banner system was shutdown with management losing access to electronic files in the system. Maintenance of proper financial records and student enrollment files in paper form were not kept by management nor was the data downloaded from Banner prior to the system being shutdown. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical financial information pertaining to the period under audit.
For one of three graduate students selected that received TEACH grant disbursements, the student’s cumulative undergraduate grade point average did not meet or exceed the GPA requirement of 3.25 on a 4.0 scale. Status: Due to the closure of the College, various software systems were shutdown without downloading data to a backup drive. In addition, sufficient paper documentation was not maintained in supporting the activity of the College for both financial transactions and remaining compliance requirements in winding down the operations. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-003 Eligibility FALN Number: 84.379 Program or Cluster Name: Teacher Education Assistance for College and Higher Education Grants (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For one of three graduate students selected that received TEACH grant disbursements, the student’s cumulative undergraduate grade point average did not meet or exceed the GPA requirement of 3.25 on a 4.0 scale. Status: Due to the closure of the College, various software systems were shutdown without downloading data to a backup drive. In addition, sufficient paper documentation was not maintained in supporting the activity of the College for both financial transactions and remaining compliance requirements in winding down the operations. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
We noted that the College did not have a policy to address student information security. Status: Due to the closure of the College, various software systems were shutdown with little consideration being given to information security and the storage of sensitive student data. Management was more concerned with recording of financial transactions and winding down operations of the College. We are unable to verify if the College is in compliance with the Program Participation Agreement and the Gramm-Leach Bliley Act. As such, the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-004 Special Test - Gramm-Leach Bliley Act FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: We noted that the College did not have a policy to address student information security. Status: Due to the closure of the College, various software systems were shutdown with little consideration being given to information security and the storage of sensitive student data. Management was more concerned with recording of financial transactions and winding down operations of the College. We are unable to verify if the College is in compliance with the Program Participation Agreement and the Gramm-Leach Bliley Act. As such, the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College )including key Information technology personnel). The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out.
2019-007
We noted that the College did not follow internal procedures to ensure that Student Financial Assistance funds were not drawn down in excess of the institution’s immediate needs for disbursement to student accounts. In addition, there was no documentation available to verify that controls over the G5 drawdowns were reviewed or approved prior to initiation. Status: Due to the closure of the College, various software systems were shutdown without downloading data to a backup drive. In addition, sufficient paper documentation was not maintained in supporting the activity of the College for both financial transactions and remaining compliance requirements in winding down the operations. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-005 Cash Management FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: We noted that the College did not follow internal procedures to ensure that Student Financial Assistance funds were not drawn down in excess of the institution’s immediate needs for disbursement to student accounts. In addition, there was no documentation available to verify that controls over the G5 drawdowns were reviewed or approved prior to initiation. Status: Due to the closure of the College, various software systems were shutdown without downloading data to a backup drive. In addition, sufficient paper documentation was not maintained in supporting the activity of the College for both financial transactions and remaining compliance requirements in winding down the operations. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
For one of eleven students selected for verification, it was noted that no evidence of review by the Financial Aid Department was performed of the verification worksheet or supporting documentation. Status: Due to the closure of the College, the review of the documents obtained during the verification process was not documented either digitally or in paper format. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-006 Special Tests - Verification FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For one of eleven students selected for verification, it was noted that no evidence of review by the Financial Aid Department was performed of the verification worksheet or supporting documentation. Status: Due to the closure of the College, the review of the documents obtained during the verification process was not documented either digitally or in paper format. Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
During our audit procedures, for three of forty students selected for testing, it was noted that refunds of credit balances created by the disbursement of Student Financial Assistance disbursements were not paid to students within fourteen days of the date the credit balance occurred. In addition, it was noted that the College follows the same process for issuing all student refunds, regardless of the Title IV status. An additional nine student refunds were not paid within fourteen days of the date the credit balance occurred. Status: Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-007 Special Tests – Disbursements to or on Behalf of Students FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: During our audit procedures, for three of forty students selected for testing, it was noted that refunds of credit balances created by the disbursement of Student Financial Assistance disbursements were not paid to students within fourteen days of the date the credit balance occurred. In addition, it was noted that the College follows the same process for issuing all student refunds, regardless of the Title IV status. An additional nine student refunds were not paid within fourteen days of the date the credit balance occurred. Status: Student and financial scholarship records could not be provided and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
2019-006
For three of seventeen student withdrawals, we were unable to verify the date of the student withdrawals or examine the Return to Title IV funds calculation for accuracy or timeliness. Status: Because of the closure of the College, individual student records including individual transaction records were not maintained either digitally or in paper format. We were unable to determine whether Return of Title IV fund calculations were required or performed accurately or timely and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-008 Special Tests – Return of Title IV Funds FALN Number: 84.268 / 84.063 Program or Cluster Name: Federal Direct Student Loan Program / Federal Pell Grant Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For three of seventeen student withdrawals, we were unable to verify the date of the student withdrawals or examine the Return to Title IV funds calculation for accuracy or timeliness. Status: Because of the closure of the College, individual student records including individual transaction records were not maintained either digitally or in paper format. We were unable to determine whether Return of Title IV fund calculations were required or performed accurately or timely and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
2019-005
For one of forty Federal Direct Student Loan Program disbursements tested, one disbursement was made to a student thirty-five days prior to the first day of classes for the applicable payment period. Status: Due to the closure of the College, individual student records including individual transaction records were not maintained either digitally or in paper format. We are unable to verify whether federal student financial assistance was disbursed to students within the required timeframe and as such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-009 Special Tests – Disbursements to and on Behalf of Students FALN Number: 84.268 Program or Cluster Name: Federal Direct Student Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For one of forty Federal Direct Student Loan Program disbursements tested, one disbursement was made to a student thirty-five days prior to the first day of classes for the applicable payment period. Status: Due to the closure of the College, individual student records including individual transaction records were not maintained either digitally or in paper format. We are unable to verify whether federal student financial assistance was disbursed to students within the required timeframe and as such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
For six of forty status changes selected for testing, no documentation was provided. For three students, no documentation of the students’ enrollment status change was provided. Twenty status changes were not reported accurately. Seventeen status changes were not reported within 60 days. We did not note any documentation of review or approval of enrollment status changes as part of the enrollment reporting process. Status: Due to the closure of the College, individual student records including individual transaction records were not maintained either digitally or in paper format. As such, we are unable to verify if internal controls over federal student financial assistance disbursements functioned properly and thus are unable to verify the correction of the finding. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-010 Special Tests – Enrollment Reporting FALN Number: 84.268 Program or Cluster Name: Federal Direct Student Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For six of forty status changes selected for testing, no documentation was provided. For three students, no documentation of the students’ enrollment status change was provided. Twenty status changes were not reported accurately. Seventeen status changes were not reported within 60 days. We did not note any documentation of review or approval of enrollment status changes as part of the enrollment reporting process. Status: Due to the closure of the College, individual student records including individual transaction records were not maintained either digitally or in paper format. As such, we are unable to verify if internal controls over federal student financial assistance disbursements functioned properly and thus are unable to verify the correction of the finding. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student financial information pertaining to the period under audit.
For three of three monthly Common Origination and Disbursement (“COD”) reconciliations requested, reconciliations were not provided. Status: Due to the closure of the College review of the documents obtained during the COD process along with the supporting documents was not documented either digitally or in paper format. As such the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-011 Special Tests – Borrower Data and Reconciliation (Direct Loans) FALN Number: 84.268 Program or Cluster Name: Federal Direct Student Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For three of three monthly Common Origination and Disbursement (“COD”) reconciliations requested, reconciliations were not provided. Status: Due to the closure of the College review of the documents obtained during the COD process along with the supporting documents was not documented either digitally or in paper format. As such the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Due to the College’s closure, there was no one remaining at the College with access to COD in order to gain access to the necessary information needed to complete the reconciliations.
The FISAP report for the 2019-2020 award year and the application for the 2021-2022 award year was submitted online by November 2, 2020, however the signature was not submitted until February 25, 2021. In addition, we noted multiple inaccuracies in the data reported on the initial FISAP report. Per inquiry of the Director of Financial Aid, corrections were made, however the corrected FISAP report was not provided, therefore we were unable to determine if the corrected FISAP was completed accurately. In addition, per inquiry of the Director of Financial Aid, there was no subsequent review of the FISAP report prior to the initial or revised submission. Status: During and leading up to the closure of the College there was a significant amount of transactions being recorded while the finance function was being transitioned to outside consultants. This led to review processes regarding financial compliance and reporting not functioning. In addition, with the closure of the College, management lost access to various software and reporting systems. Maintenance of proper records in paper form were not kept by management nor was the data downloaded from the software prior to access being disabled. As such, the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-012 Special Reporting FALN Number: 84.007 Program or Cluster Name: Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: The FISAP report for the 2019-2020 award year and the application for the 2021-2022 award year was submitted online by November 2, 2020, however the signature was not submitted until February 25, 2021. In addition, we noted multiple inaccuracies in the data reported on the initial FISAP report. Per inquiry of the Director of Financial Aid, corrections were made, however the corrected FISAP report was not provided, therefore we were unable to determine if the corrected FISAP was completed accurately. In addition, per inquiry of the Director of Financial Aid, there was no subsequent review of the FISAP report prior to the initial or revised submission. Status: During and leading up to the closure of the College there was a significant amount of transactions being recorded while the finance function was being transitioned to outside consultants. This led to review processes regarding financial compliance and reporting not functioning. In addition, with the closure of the College, management lost access to various software and reporting systems. Maintenance of proper records in paper form were not kept by management nor was the data downloaded from the software prior to access being disabled. As such, the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
For nine of forty students selected for testing, we were unable to resolve questions relating to satisfactory academic progress. Status: Student and financial scholarship records could not be provided and thus we were unable to determine that students were making satisfactory academic progress, and therefore eligible to receive the Federal Student Financial Assistance received. As such, the correction of the finding could not be verified. See current year finding 2021-002.
Show full finding ▾Hide full finding ▴2020-013 Eligibility & Special Tests – Institutional Eligibility FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Condition: For nine of forty students selected for testing, we were unable to resolve questions relating to satisfactory academic progress. Status: Student and financial scholarship records could not be provided and thus we were unable to determine that students were making satisfactory academic progress, and therefore eligible to receive the Federal Student Financial Assistance received. As such, the correction of the finding could not be verified. See current year finding 2021-002.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.
Because of the closure of the College, we were unable to obtain sufficient audit evidence of student records to test the compliance of direct and material compliance requirements which were identified as activities allowed or unallowed, cash management, eligibility, reporting, and special tests and provisions. In addition, management was unable to provide sufficient documentation to support the reconciliation of the schedule of expenditures of federal awards to the College’s accounts and records. Further, we noted that the management did not submit the data collection form to the Federal Audit Clearinghouse in a timely manner. Cause: Due to the closure of the College, Ellucian Banner (“Banner”), the accounting and financial system for the College was shut down in preparing for the upcoming shutdown of the College. Management lost access to electronic files in Banner and proper maintenance of student records were neither maintained by management nor was the data downloaded from Banner prior to the system being shut down. Effect: The lack of a formal closing process and lack of maintenance of sufficient documentation for student records made it impossible for us to obtain sufficient audit evidence of student records to test the compliance of direct and material compliance requirements. In addition, we were unable to test the completeness of the schedule of expenditures of federal awards since it did not reconcile to tuition revenue as reflected in the College’s accounts and records. Lastly, management was unable to submit the data collection form to the Federal Audit Clearinghouse by the required due date. Repeat Finding: No Recommendation: We recommend that the outsourced financial consultants and those charged with governance maintain proper student records as the College continues with its liquidation. In addition, we recommend the schedule of expenditures of federal awards be reconciled to the College’s accounts and records. Finally, management should ensure that future data collection forms that may be required to be submitted are done so on a timely basis. Management’s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2021-002 Noncompliance with Uniform Grant Guidance Requirements FALN Number: 84.268 / 84.063 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: To comply with the Student Financial Aid Cluster requirements, institutions must follow direct and material compliance requirements as outlined in the OMB Compliance Supplement. In addition, entities subject to an audit in accordance with Uniform Grant Guidance are required to submit the Data Collection Form with the Federal Audit Clearinghouse. We were engaged to express an opinion on the College’s compliance with direct and material compliance requirements for Student Financial Assistance Cluster. Furthermore, to ensure completeness of the schedule of expenditures of federal awards and appropriate recognition of revenue from Federal awards is reflected in the College’s accounting records, the expenditures on the schedule of expenditure of federal awards should be reconciled to the College’s accounts and records. Condition: Because of the closure of the College, we were unable to obtain sufficient audit evidence of student records to test the compliance of direct and material compliance requirements which were identified as activities allowed or unallowed, cash management, eligibility, reporting, and special tests and provisions. In addition, management was unable to provide sufficient documentation to support the reconciliation of the schedule of expenditures of federal awards to the College’s accounts and records. Further, we noted that the management did not submit the data collection form to the Federal Audit Clearinghouse in a timely manner. Cause: Due to the closure of the College, Ellucian Banner (“Banner”), the accounting and financial system for the College was shut down in preparing for the upcoming shutdown of the College. Management lost access to electronic files in Banner and proper maintenance of student records were neither maintained by management nor was the data downloaded from Banner prior to the system being shut down. Effect: The lack of a formal closing process and lack of maintenance of sufficient documentation for student records made it impossible for us to obtain sufficient audit evidence of student records to test the compliance of direct and material compliance requirements. In addition, we were unable to test the completeness of the schedule of expenditures of federal awards since it did not reconcile to tuition revenue as reflected in the College’s accounts and records. Lastly, management was unable to submit the data collection form to the Federal Audit Clearinghouse by the required due date. Repeat Finding: No Recommendation: We recommend that the outsourced financial consultants and those charged with governance maintain proper student records as the College continues with its liquidation. In addition, we recommend the schedule of expenditures of federal awards be reconciled to the College’s accounts and records. Finally, management should ensure that future data collection forms that may be required to be submitted are done so on a timely basis. Management’s Response: See corrective action plan attached.
Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical financial information pertaining to the period under audit.
FAC accepted this audit on January 22, 2023 — management decision was due July 22, 2023.
The College relies upon flag reports generated by the College?s Banner system to verify and monitor the eligibility of students to receive Federal Student Financial Assistance awards. The Director of Financial Aid receives and reviews the students flagged with eligibility exceptions that need to be resolved before Federal Student Financial Assistance is disbursed. Based upon the review and resolution of eligibility flags, Federal Student Financial Assistance is disbursed, or the student is determined to be ineligible for Federal Student Financial Assistance. The Director of Financial Aid was unable to provide copies of exception reports, therefore we were unable to determine if controls over eligibility were in place and operating effectively. Cause: Due to the impending closure of the College, the Director of Financial Aid was terminated and access to student eligibility flag reports were not able to be located. Effect: Controls over eligibility were unable to be verified. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College develop procedures to ensure that all documents obtained or prepared as part of the eligibility determination process are retained and stored for future review. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-002 Eligibility CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Institutions of Higher Education must ensure that its administrative procedures for Student Financial Assistance programs include an adequate system of internal controls to prevent or detect noncompliance on a timely basis. The system of internal controls should also include procedures to ensure that all employees have access to information to perform their duties, as well as necessary for audit or other review procedures. Condition: The College relies upon flag reports generated by the College?s Banner system to verify and monitor the eligibility of students to receive Federal Student Financial Assistance awards. The Director of Financial Aid receives and reviews the students flagged with eligibility exceptions that need to be resolved before Federal Student Financial Assistance is disbursed. Based upon the review and resolution of eligibility flags, Federal Student Financial Assistance is disbursed, or the student is determined to be ineligible for Federal Student Financial Assistance. The Director of Financial Aid was unable to provide copies of exception reports, therefore we were unable to determine if controls over eligibility were in place and operating effectively. Cause: Due to the impending closure of the College, the Director of Financial Aid was terminated and access to student eligibility flag reports were not able to be located. Effect: Controls over eligibility were unable to be verified. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College develop procedures to ensure that all documents obtained or prepared as part of the eligibility determination process are retained and stored for future review. Management?s Response: See corrective action plan attached.
2020-002 Eligibility CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Institutions of Higher Education must ensure that its administrative procedures for Student Financial Assistance programs include an adequate system of internal controls to prevent or detect noncompliance on a timely basis. The system of internal controls should also include procedures to ensure that all employees have access to information to perform their duties, as well as necessary for audit or other review procedures. Condition: The College relies upon flag reports generated by the College?s Banner system to verify and monitor the eligibility of students to receive Federal Student Financial Assistance awards. The Director of Financial Aid receives and reviews the students flagged with eligibility exceptions that need to be resolved before Federal Student Financial Assistance is disbursed. Based upon the review and resolution of eligibility flags, Federal Student Financial Assistance s disbursed, or the student is determined to be ineligible for Federal Student Financial Assistance. The Director of Financial Aid was unable to provide copies of exception reports, therefore we were unable to determine if controls over eligibility were in place and operating effectively. Cause: Due to the impending closure of the College, the Director of Financial Aid was terminated and access to student eligibility flag reports, were not able to be located. Effect: Controls over eligibility were unable to be verified. Questioned Costs: None. Recommendation: We recommend that the College develop procedures to ensure that all documents obtained or prepared as part of the eligibility determination process are retained and stored for future review. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
For one of three graduate students selected that received TEACH grant disbursements, the student?s cumulative undergraduate grade point average did not meet or exceed the GPA requirement of 3.25 on a 4.0 scale. Cause: Although the College obtained the student?s undergraduate transcript, the student?s GPA was not reviewed as part of the eligibility determination process due to administrative oversight. Effect: One student received TEACH grant disbursements that was not eligible. Questioned Costs: $3,752 Repeat Finding: No. Recommendation: We recommend that procedures are put in place to ensure that all students receiving TEACH grants meet the GPA requirement of 3.25 on a 4.0 scale. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-003 Eligibility CFDA Number: 84.379 Program or Cluster Name: Teacher Education Assistance for College and Higher Education Grants (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: To be eligible to receive a Teacher Education Assistance for College and Higher Education (?TEACH?) grant, a student enrolled in a graduate program must have a cumulative undergraduate grade point average (?GPA?) of at least 3.25 on a 4.0 scale, or the numeric equivalent. Condition: For one of three graduate students selected that received TEACH grant disbursements, the student?s cumulative undergraduate grade point average did not meet or exceed the GPA requirement of 3.25 on a 4.0 scale. Cause: Although the College obtained the student?s undergraduate transcript, the student?s GPA was not reviewed as part of the eligibility determination process due to administrative oversight. Effect: One student received TEACH grant disbursements that was not eligible. Questioned Costs: $3,752 Repeat Finding: No. Recommendation: We recommend that procedures are put in place to ensure that all students receiving TEACH grants meet the GPA requirement of 3.25 on a 4.0 scale. Management?s Response: See corrective action plan attached.
2020-003 Eligibility CFDA Number: 84.379 Program or Cluster Name: Teacher Education Assistance for College and Higher Education Grants (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: To be eligible to receive a Teacher Education Assistance for College and Higher Education (?TEACH?) grant, a student enrolled in a graduate program must have a cumulative undergraduate grade point average (?GPA?) of at least 3.25 on a 4.0 scale, or the numeric equivalent. Condition: For one of three graduate students selected that received TEACH grant disbursements, the student?s cumulative undergraduate grade point average did not meet or exceed the GPA requirement of 3.25 on a 4.0 scale. Cause: Although the College obtained the student?s undergraduate transcript, the student?s GPA was not reviewed as part of the eligibility determination process due to administrative oversight. Effect: One student received TEACH grant disbursements that was not eligible. Questioned Costs: $3,752 Repeat Finding: No. Recommendation: We recommend that procedures are put in place to ensure that all students receiving TEACH grants meet the GPA requirement of 3.25 on a 4.0 scale. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
We noted that the College did not have a policy to address student information security. Cause: Management has not updated student privacy policies to comply with the GLBA. Effect: The College is not in compliance with the Program Participation Agreement and the GLBA. Questioned Costs: None. Repeat Finding: Yes, see finding 2019-007. Recommendation: We recommend that the College develop and implement a policy to comply with the GLBA. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-004 Special Test - Gramm-Leach Bliley Act CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The Gramm-Leach-Bliley Act (?GLBA?) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of federal student financial aid programs. Condition: We noted that the College did not have a policy to address student information security. Cause: Management has not updated student privacy policies to comply with the GLBA. Effect: The College is not in compliance with the Program Participation Agreement and the GLBA. Questioned Costs: None. Repeat Finding: Yes, see finding 2019-007. Recommendation: We recommend that the College develop and implement a policy to comply with the GLBA. Management?s Response: See corrective action plan attached.
2020-004 Special Test - Gramm-Leach Bliley Act CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The Gramm-Leach-Bliley Act (?GLBA?) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under an institution?s Program Participation Agreement with the Department of Education and the GLBA, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of federal student financial aid programs. Condition: We noted that the College did not have a policy to address student information security. Cause: Management has not updated student privacy policies to comply with the GLBA Effect: The College is not in compliance with the Program Participation Agreement and the GLBA. Questioned Costs: None. Repeat Finding: Yes, see finding 2019-007. Recommendation: We recommend that the College develop and implement a policy to comply with the GLBA. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
2019-007
We noted that the College did not follow internal procedures to ensure that Student Financial Assistance funds were not drawn down in excess of the institution?s immediate needs for disbursement to student accounts. In addition, there was no documentation available to verify that controls over the G5 drawdowns were reviewed or approved prior to initiation. Cause: Internal procedures over cash management did not operate effectively. Effect: We were unable to verify that controls over cash management were operating as designed. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College enhance internal procedures to ensure that cash draw downs are not requested unless there is an immediate need for disbursement to student accounts. In addition, procedures should include the method of documenting the request for and approval of G5 draw downs prior to initiation of draw downs. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-005 Cash Management CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: An institution?s request to draw down Student Financial Assistance funds must not exceed the amount it immediately needs for disbursements the institution has made or will make to eligible students or parents, or for other allowable activities. Condition: We noted that the College did not follow internal procedures to ensure that Student Financial Assistance funds were not drawn down in excess of the institution?s immediate needs for disbursement to student accounts. In addition, there was no documentation available to verify that controls over the G5 drawdowns were reviewed or approved prior to initiation. Cause: Internal procedures over cash management did not operate effectively. Effect: We were unable to verify that controls over cash management were operating as designed. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College enhance internal procedures to ensure that cash draw downs are not requested unless there is an immediate need for disbursement to student accounts. In addition, procedures should include the method of documenting the request for and approval of G5 draw downs prior to initiation of draw downs. Management?s Response: See corrective action plan attached.
2020-005 Cash Management CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: An institution?s request to draw down Student Financial Assistance funds must not exceed the amount it immediately needs for disbursements the institution has made or will make to eligible students or parents, or for other allowable activities. Condition: We noted that the College did not follow internal procedures to ensure that Student Financial Assistance funds were not drawn down in excess of the institution?s immediate needs for disbursement to student accounts. In addition, there was no documentation available to verify that controls over the G5 drawdowns were reviewed or approved prior to initiation. Cause: Internal procedures over cash management did not operate effectively. Effect: We were unable to verify that controls over cash management were operating as designed. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College enhance internal procedures to ensure that cash draw downs are not requested unless there is an immediate need for disbursement student accounts. In addition, procedures should include the method of documenting the request for and approval of G5 draw downs prior to initiation of draw downs. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
For one of eleven students selected for verification, it was noted that no evidence of review by the Financial Aid Department was performed of the verification worksheet or supporting documentation. Cause: Review of the documents obtained during the verification process was not documented due to administrative oversight. Effect: We are unable to verify that the review of the verification documentation for the selected student was performed. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that internal policies are enhanced to include the documentation requirements for the review of documents received as part of the verification requirements. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-006 Special Tests - Verification CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Students selected for verification by the U.S. Department of Education as indicated on the ISIR must provide additional documentation to verify specific personal information submitted on the student?s FAFSA. Additional documentation provided must be matched to the information on the student?s ISIR, and corrections must be made if necessary. Condition: For one of eleven students selected for verification, it was noted that no evidence of review by the Financial Aid Department was performed of the verification worksheet or supporting documentation. Cause: Review of the documents obtained during the verification process was not documented due to administrative oversight. Effect: We are unable to verify that the review of the verification documentation for the selected student was performed. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that internal policies are enhanced to include the documentation requirements for the review of documents received as part of the verification requirements. Management?s Response: See corrective action plan attached.
2020-006 Special Tests - Verification CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Students selected for verification by the U.S. Department of Education as indicated on the ISIR must provide additional documentation to verify specific personal information submitted on the student?s FAFSA. Additional documentation provided must be matched to the information on the student?s ISIR, and corrections must be made if necessary. Condition: For one of eleven students selected for verification, it was noted that no evidence of review by the Financial Aid Department was performed of the verification worksheet or supporting documentation. Cause: Review of the documents obtained during the verification process was not documented due to administrative oversight. Effect: We are unable to verify that the review of the verification documentation for the selected student was performed. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that internal policies are enhanced to include the documentation requirements for the review of documents received as part of the verification requirements. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
During our audit procedures, for three of forty students selected for testing, it was noted that refunds of credit balances created by the disbursement of Student Financial Assistance disbursements were not paid to students within fourteen days of the date the credit balance occurred. In addition, it was noted that the College follows the same process for issuing all student refunds, regardless of the Title IV status. An additional nine student refunds were not paid within fourteen days of the date the credit balance occurred. Cause: Refund requests were not processed on a weekly basis according to College processes and policies, delaying the issuance of refund checks to students. Effect: Internal controls over refunds of credit balances created by the disbursement of Student Financial Assistance funds did not function properly. As a result, credit balances were not paid directly to students within the required timeframe for three students. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2019-006. Recommendation: We recommend that the College review and enhance procedures in place to ensure that refunds of credit balances created by the disbursement of Student Financial Assistance funds are paid directly to students within the required timeframe. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-007 Special Tests ? Disbursements to or on Behalf of Students CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: When Student Financial Assistance disbursements to a student?s account creates a credit balance, the credit balance must be paid directly to the student or parent as soon as possible, but no later than fourteen days after the credit balance occurred. Condition: During our audit procedures, for three of forty students selected for testing, it was noted that refunds of credit balances created by the disbursement of Student Financial Assistance disbursements were not paid to students within fourteen days of the date the credit balance occurred. In addition, it was noted that the College follows the same process for issuing all student refunds, regardless of the Title IV status. An additional nine student refunds were not paid within fourteen days of the date the credit balance occurred. Cause: Refund requests were not processed on a weekly basis according to College processes and policies, delaying the issuance of refund checks to students. Effect: Internal controls over refunds of credit balances created by the disbursement of Student Financial Assistance funds did not function properly. As a result, credit balances were not paid directly to students within the required timeframe for three students. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2019-006. Recommendation: We recommend that the College review and enhance procedures in place to ensure that refunds of credit balances created by the disbursement of Student Financial Assistance funds are paid directly to students within the required timeframe. Management?s Response: See corrective action plan attached.
2020-007 Special Tests ? Disbursements to or on Behalf of Students CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: When Student Financial Assistance disbursements to a student?s account creates a credit balance, the credit balance must be paid directly to the student or parent as soon as possible, but no later than fourteen days after the credit balance occurred. Condition: During our audit procedures, for three of forty students selected for testing, it was noted that refunds of credit balances created by the disbursement of Student Financial Assistance disbursements were not paid to students within fourteen days of the date the credit balance occurred. In addition, it was noted that the College follows the same process for issuing all student refunds, regardless of the Title IV status. An additional eleven student refunds were not paid within fourteen days of the date the credit balance occurred. Cause: Refund requests were not processed on a weekly basis according to College processes and policies, delaying the issuance of refund checks to students. Effect: Internal controls over refunds of credit balances created by the disbursement of Student Financial Assistance funds did not function properly. As a result, credit balances were not paid directly to students within the required timeframe for three students. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2019-006. Recommendation: We recommend that the College review and enhance procedures in place to ensure that refunds of credit balances created by the disbursement of Student Financial Assistance funds are paid directly to students within the required timeframe. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
2019-006
For three of seventeen student withdrawals, we were unable to verify the date of the student withdrawals or examine the Return to Title IV funds calculation for accuracy or timeliness. Cause: Due to the impending closure of the College and the termination of multiple employees involved in the Return of Title IV Funds process prior to completion of audit procedures, we were unable to obtain complete documentation related to our sample. Effect: We were unable to determine whether Return of Title IV fund calculations were required or performed accurately or timely for three students. Questioned Costs: None. Repeat Finding: Yes, see finding 2019-005. Recommendation: We recommend that the College strengthen their controls over the Return of Title IV Funds process to ensure that documentation relating to student withdrawals and the calculation and return of Title IV funds not earned is performed accurately and timely. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-008 Special Tests ? Return of Title IV Funds CFDA Number: 84.268 / 84.063 Program or Cluster Name: Federal Direct Student Loan Program / Federal Pell Grant Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Condition: For three of seventeen student withdrawals, we were unable to verify the date of the student withdrawals or examine the Return to Title IV funds calculation for accuracy or timeliness. Cause: Due to the impending closure of the College and the termination of multiple employees involved in the Return of Title IV Funds process prior to completion of audit procedures, we were unable to obtain complete documentation related to our sample. Effect: We were unable to determine whether Return of Title IV fund calculations were required or performed accurately or timely for three students. Questioned Costs: None. Repeat Finding: Yes, see finding 2019-005. Recommendation: We recommend that the College strengthen their controls over the Return of Title IV Funds process to ensure that documentation relating to student withdrawals and the calculation and return of Title IV funds not earned is performed accurately and timely. Management?s Response: See corrective action plan attached.
2020-008 Special Tests ? Return of Title IV Funds CFDA Number: 84.268 / 84.063 Program or Cluster Name: Federal Direct Loan Program / Federal Pell Grant Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Condition: For three of seventeen student withdrawals, we were unable to verify the date of the student withdrawals or examine the Return to Title IV funds calculation for accuracy or timeliness. Cause: Due to the impending closure of the College and the termination of multiple employees involved in the Return of Title IV Funds process prior to completion of audit procedures, we were unable to obtain complete documentation related to our sample. Effect: We were unable to determine whether Return of Title IV fund calculations were required or performed accurately or timely for three students. Questioned Costs: $18,656 Repeat Finding: Yes, see finding 2019-005. Recommendation: We recommend that the College strengthen their controls over the Return of Title IV Funds process to ensure that documentation relating to student withdrawals and the calculation and return of Title IV funds not earned is performed accurately and timely. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
2019-005
For one of forty Federal Direct Student Loan Program disbursements tested, one disbursement was made to a student thirty-five days prior to the first day of classes for the applicable payment period. Cause: Internal controls over federal student financial assistance disbursements did not function effectively. Effect: Federal student financial assistance was not disbursed to one student within the required timeframe. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that Student Financial Assistance fund disbursements are not made more than ten days from the start of classes. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-009 Special Tests ? Disbursements to and on Behalf of Students CFDA Number: 84.268 Program or Cluster Name: Federal Direct Student Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The earliest an institution may disburse Student Financial Assistance Funds is ten days before the first day of classes of the payment period for which the disbursement is intended. Condition: For one of forty Federal Direct Student Loan Program disbursements tested, one disbursement was made to a student thirty-five days prior to the first day of classes for the applicable payment period. Cause: Internal controls over federal student financial assistance disbursements did not function effectively. Effect: Federal student financial assistance was not disbursed to one student within the required timeframe. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that Student Financial Assistance fund disbursements are not made more than ten days from the start of classes. Management?s Response: See corrective action plan attached.
2020-009 Special Tests ? Disbursements to and on Behalf of Students CFDA Number: 84.268 Program or Cluster Name: Federal Direct Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The earliest an institution may disburse Student Financial Assistance Funds is ten days before the first day of classes of the payment period for which the disbursement is intended. Condition: For one of forty Federal Direct Loan Program disbursements tested, one disbursement was made to a student thirty-five days prior to the first day of classes for the applicable payment period. Cause: Internal controls over federal student financial assistance disbursements did not function effectively. Effect:. Federal student financial assistance was not disbursed to one student within the required timeframe. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that Student Financial Assistance fund disbursements are not made more than 10 days from the start of classes. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
For six of forty status changes selected for testing, no documentation was provided. For three students, no documentation of the students? enrollment status change was provided. Twenty status changes were not reported accurately. Seventeen status changes were not reported within 60 days. We did not note any documentation of review or approval of enrollment status changes as part of the enrollment reporting process. Cause: Internal controls over the enrollment reporting process were not functioning effectively. Effect: Internal controls over federal student financial assistance disbursements did not function properly. As a result, aid was not disbursed to one student according to the required timeframe. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that student enrollment status changes are reported accurately and timely, and that documentation relating to status changes are retained. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-010 Special Tests ? Enrollment Reporting CFDA Number: 84.268 Program or Cluster Name: Federal Direct Student Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant Program and the Federal Direct Loan Program via the National Student Loan Data System (?NSLDS?). Institutions are responsible for accurately reporting the type of enrollment status changes and the effective date of the status change. These enrollment updates must be reported to the NSLDS within 60 days of the date of status change. In addition, institutions must return the bi-monthly enrollment roster to the NSLDS within 15 days of the date that the roster was sent to the institution. Condition: For six of forty status changes selected for testing, no documentation was provided. For three students, no documentation of the students? enrollment status change was provided. Twenty status changes were not reported accurately. Seventeen status changes were not reported within 60 days. We did not note any documentation of review or approval of enrollment status changes as part of the enrollment reporting process. Cause: Internal controls over the enrollment reporting process were not functioning effectively. Effect: Internal controls over federal student financial assistance disbursements did not function properly. As a result, aid was not disbursed to one student according to the required timeframe. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that student enrollment status changes are reported accurately and timely, and that documentation relating to status changes are retained. Management?s Response: See corrective action plan attached.
2020-010 Special Tests ? Enrollment Reporting CFDA Number: 84.268 Program or Cluster Name: Federal Direct Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Institutions are required to report enrollment information under the Pell grant and the Federal Direct Loan Program via the National Student Loan Data System (?NSLDS?). Institutions are responsible for accurately reporting the type of enrollment status changes and the effective date of the status change. These enrollment updates must be reported to the NSLDS within 60 days of the date of status change. In addition, institutions must return the bi-monthly enrollment roster to the NSLDS within 15 days of the date that the roster was sent to the institution. Condition: For six of forty status changes selected for testing, no documentation was provided. In addition, we noted for two students that the NSLDS Enrollment Detail did not indicate that Concordia College was an institution at which the student was enrolled. Five students with a graduated enrollment status change did not have a graduated enrollment status updated on the NSLDS Enrollment Detail. For three students, no documentation of the students? enrollment status change was provided. Thirteen status changes were not reported accurately. Seventeen status changes were not reported within 60 days. Cause: Internal controls over the enrollment reporting process were not functioning effectively. Effect: Internal controls over federal student financial assistance disbursements did not function properly. As a result, aid was not disbursed to one student according to the required timeframe. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that student enrollment status changes are reported accurately and timely, and that documentation relating to status changes are retained. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
For three of three monthly COD reconciliations requested, reconciliations were not provided. Cause: Internal controls over borrower data and reconciliation did not function effectively. Effect: Institutional financial records were not reconciled to the COD system on a monthly basis. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that disbursements of Federal Direct Student Loan Program funds are reported timely to COD. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-011 Special Tests ? Borrower Data and Reconciliation (Direct Loans) CFDA Number: 84.268 Program or Cluster Name: Federal Direct Student Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The institution must reconcile the institutional financial records to the Common Origination and Disbursement (?COD?) system on a monthly basis. Condition: For three of three monthly COD reconciliations requested, reconciliations were not provided. Cause: Internal controls over borrower data and reconciliation did not function effectively. Effect: Institutional financial records were not reconciled to the COD system on a monthly basis. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that disbursements of Federal Direct Student Loan Program funds are reported timely to COD. Management?s Response: See corrective action plan attached.
2020-011 Special Tests ? Borrower Data and Reconciliation (Direct Loans) CFDA Number: 84.268 Program or Cluster Name: Federal Direct Loan Program (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The institution must reconcile the institutional financial records to the Common Origination and Disbursement (?COD?) system on a monthly basis. Condition: For three of three monthly COD reconciliations requested, reconciliations were not provided. Cause: Internal controls over borrower data and reconciliation did not function effectively. Effect: Institutional financial records were not reconciled to the COD system on a monthly basis. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that disbursements of Federal Direct Loan Program funds are reported timely to COD. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
The FISAP report for the 2019-2020 award year and the application for the 2021-2022 award year was submitted online by November 2, 2020, however the signature was not submitted until February 25, 2021. In addition, we noted multiple inaccuracies in the data reported on the initial FISAP report. Per inquiry of the Director of Financial Aid, corrections were made, however the corrected FISAP report was not provided, therefore we were unable to determine if the corrected FISAP was completed accurately. In addition, per inquiry of the Director of Financial Aid, there was no subsequent review of the FISAP report prior to the initial or revised submission. Cause: Internal controls over the FISAP report were not in place or operating effectively. In addition, the subsequent termination of the Director of Financial Aid related to the impending closure of the College prevented access to various documents and systems. Effect: The FISAP submission was not completed by the required deadline of November 2, 2020. In addition, we were not able to verify the accuracy of the information submitted on the FISAP report. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that disbursements of the FISAP report is filed timely and accurately. This should include a review process by an independent individual with the knowledge and experience in order to perform an adequate review of the report. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-012 Special Reporting CFDA Number: 84.033 / 84.007 Program or Cluster Name: Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The institution must submit the Fiscal Operations Report and Application to Participate (?FISAP?) annually to receive funds for the campus-based programs. The FISAP report for the 2019-2020 award year and application for the 2021-2022 award year was required to be filed by November 2, 2020. Institutions were permitted to submit corrections to the FISAP until December 15, 2020. Condition: The FISAP report for the 2019-2020 award year and the application for the 2021-2022 award year was submitted online by November 2, 2020, however the signature was not submitted until February 25, 2021. In addition, we noted multiple inaccuracies in the data reported on the initial FISAP report. Per inquiry of the Director of Financial Aid, corrections were made, however the corrected FISAP report was not provided, therefore we were unable to determine if the corrected FISAP was completed accurately. In addition, per inquiry of the Director of Financial Aid, there was no subsequent review of the FISAP report prior to the initial or revised submission. Cause: Internal controls over the FISAP report were not in place or operating effectively. In addition, the subsequent termination of the Director of Financial Aid related to the impending closure of the College prevented access to various documents and systems. Effect: The FISAP submission was not completed by the required deadline of November 2, 2020. In addition, we were not able to verify the accuracy of the information submitted on the FISAP report. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that disbursements of the FISAP report is filed timely and accurately. This should include a review process by an independent individual with the knowledge and experience in order to perform an adequate review of the report. Management?s Response: See corrective action plan attached.
2020-012 Special Reporting CFDA Number: 84.033 / 84.007 Program or Cluster Name: Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: The institution must submit the Fiscal Operations Report and Application to Participate (?FISAP?) annually to receive funds for the campus-based programs. The FISAP report for the 2019-2020 award year and application for the 2021-2022 award year was required to be filed by November 2, 2020. Institutions were permitted to submit corrections to the FISAP until December 15, 2020. Condition: The FISAP report for the 2019-2020 award year and the application for the 2021-2022 award year was submitted online by November 2, 2020, however the signature was not submitted until February 25, 2021. In addition, we noted multiple inaccuracies in the data reported on the initial FISAP report. Per inquiry of the Director of Financial Aid, corrections were made, however the corrected FISAP report was not provided, therefore we were unable to determine if the corrected FISAP was completed accurately. In addition, per inquiry of the Director of Financial Aid, there was no subsequent review of the FISAP report prior to the initial or revised submission. Cause: Internal controls over the FISAP report were not in place or operating effectively. In addition, the subsequent termination of the Director of Financial Aid related to the impending closure of the College prevented access to various documents and systems. Effect: The FISAP submission was not completed by the required deadline of November 2, 2020. In addition, we were not able to verify the accuracy of the information submitted on the FISAP report. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the College review and enhance procedures in place to ensure that disbursements of the FISAP report is filed timely and accurately. This should include a review process by an independent individual with the knowledge and experience in order to perform an adequate review of the report. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
For nine of forty students selected for testing, we were unable to resolve questions relating to satisfactory academic progress. Cause: Due to the impending closure of the College, various individuals were terminated from the College, and system access was restricted, preventing access to certain satisfactory academic progress records at the time of fieldwork. Effect: We were unable to resolve questions for nine of forty students selected for testing regarding satisfactory academic progress. We were therefore unable to determine that these students were making satisfactory academic progress, and therefore eligible to receive the Federal Student Financial Assistance received. Questioned Costs: $81,268 Repeat Finding: No. Recommendation: We recommend that the College ensure that all documentation for determining that students met the required satisfactory academic progress standards relating to institutional and student eligibility are accessible for review as necessary. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴2020-013 Eligibility & Special Tests ? Institutional Eligibility CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Institutions must establish and publish reasonable standards for measuring whether students are maintaining satisfactory progress in their educational program. Students must make satisfactory academic progress in order to be eligible for Federal Student Financial Assistance. Condition: For nine of forty students selected for testing, we were unable to resolve questions relating to satisfactory academic progress. Cause: Due to the impending closure of the College, various individuals were terminated from the College, and system access was restricted, preventing access to certain satisfactory academic progress records at the time of fieldwork. Effect: We were unable to resolve questions for nine of forty students selected for testing regarding satisfactory academic progress. We were therefore unable to determine that these students were making satisfactory academic progress, and therefore eligible to receive the Federal Student Financial Assistance received. Questioned Costs: $81,268 Repeat Finding: No. Recommendation: We recommend that the College ensure that all documentation for determining that students met the required satisfactory academic progress standards relating to institutional and student eligibility are accessible for review as necessary. Management?s Response: See corrective action plan attached.
2020-013 Eligibility & Special Tests ? Institutional Eligibility CFDA Number: 84.268 / 84.063 / 84.033 / 84.007 / 84.379 Program or Cluster Name: Federal Direct Student Loans / Federal Pell Grant Program / Federal Work-Study Program / Federal Supplemental Educational Opportunity Grants / Teacher Education Assistance for College and Higher Education (Student Financial Assistance Cluster) Agency: U.S. Department of Education Criteria: Institutions must establish and publish reasonable standards for measuring whether students are maintaining satisfactory progress in their educational program. Students must make satisfactory academic progress in order to be eligible for Federal Student Financial Assistance. Condition: For nine of forty students selected for testing, we were unable to resolve questions relating to satisfactory academic progress. Cause: Due to the impending closure of the College, various individuals were terminated from the College, and system access was restricted, preventing access to certain satisfactory academic progress records at the time of fieldwork. Effect: We were unable to resolve questions for nine of forty students selected for testing were making satisfactory academic progress. We were therefore unable to determine that these students were making satisfactory academic progress, and therefore eligible to receive the Federal Student Financial Assistance received. Questioned Costs: $81,268 Repeat Finding: No. Recommendation: We recommend that the College ensure that all documentation relating to institutional and student eligibility are accessible for review as necessary. Management?s Response: Management agrees with the finding above. Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements.
FAC accepted this audit on April 28, 2020 — management decision was due October 28, 2020.
We noted that one of ten of the students withdrawals selected did not have a Return of Title IV calculation performed. Cause: The calculation was performed in Banner in simulation mode which resulted in the calculation not being retained and funds being returned. Effect: The student?s title IV funds were not returned to the U.S. Department of Education by the prescribed deadline. Questioned Costs: $3,203 Recommendation: We recommend that the College strengthen their controls over the student refund process to ensure that student refunds are issued in accordance with the U.S. Department of Education requirement. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Condition: We noted that one of ten of the students withdrawals selected did not have a Return of Title IV calculation performed. Cause: The calculation was performed in Banner in simulation mode which resulted in the calculation not being retained and funds being returned. Effect: The student?s title IV funds were not returned to the U.S. Department of Education by the prescribed deadline. Questioned Costs: $3,203 Recommendation: We recommend that the College strengthen their controls over the student refund process to ensure that student refunds are issued in accordance with the U.S. Department of Education requirement. Management?s Response: See corrective action plan attached.
Management agrees with this recommendation. To ensure the process is followed going forward, all counselors have been trained on how to process refunds.
We noted that fifteen of thirty four student credit balances examined were not refunded to the student within fourteen business days. Cause: Refund requests were not processed on a weekly basis according to College processes and policies, delaying the issuance of refund checks to students. Effect: The students did not receive a refund of their credit balance within fourteen days. Questioned Costs: None. Recommendation: We recommend that the College put a process in place to ensure that all students who cease enrollment with the College during an enrollment period are detected and calculations are performed and funds are returned in accordance with the U.S. Department of Education requirements. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Criteria: The U.S. Department of Education requires that student account credit balances occurring as a result of receiving Federal Student Financial Assistance must be returned to the student within fourteen days of the date that the credit balance occurred. Condition: We noted that fifteen of thirty four student credit balances examined were not refunded to the student within fourteen business days. Cause: Refund requests were not processed on a weekly basis according to College processes and policies, delaying the issuance of refund checks to students. Effect: The students did not receive a refund of their credit balance within fourteen days. Questioned Costs: None. Recommendation: We recommend that the College put a process in place to ensure that all students who cease enrollment with the College during an enrollment period are detected and calculations are performed and funds are returned in accordance with the U.S. Department of Education requirements. Management?s Response: See corrective action plan attached.
Management agrees with this recommendation. The Associate Dean of Enrollment Services & Academic Operations will notify the financial aid department when a student has been officially withdrawn from the College. Financial aid staff will run the appropriate Banner process on the withdrawal date, send updated loan information to DOE, and run a bi-weekly report to ensure that Title IV aid has been returned to DOE.
We noted that the College did not have a policy to address student information security. Cause: Management has not updated student privacy policies to comply with the Gramm-Leach-Bliley Act. Effect: The College is not in compliance with the Program Participation Agreement and the Gramm-Leach-Bliley Act. Questioned Costs: None. Recommendation: We recommend that the College develop and implement a policy to comply with the Gramm-Leach-Bliley Act. Management?s Response: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Criteria: The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of federal student financial aid programs. Condition: We noted that the College did not have a policy to address student information security. Cause: Management has not updated student privacy policies to comply with the Gramm-Leach-Bliley Act. Effect: The College is not in compliance with the Program Participation Agreement and the Gramm-Leach-Bliley Act. Questioned Costs: None. Recommendation: We recommend that the College develop and implement a policy to comply with the Gramm-Leach-Bliley Act. Management?s Response: See corrective action plan attached.
The financial aid department has provided GLBA information to be added to the College website, Course Catalog, and Student Handbook. This information has also been provided to the Director of Compliance, as it involves the handling of employee and student information. Additionally, since the GLBA works in conjunction with FERPA, the Registrar will include GLBA information in an annual notification to students.
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