EIN: 132590811
UEI: L7GDRSYKXMA1
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 24, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 24, 2026 (124 days from today).
What is a management decision? →Finding 2025-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K263382 2025 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), for students who withdrew, graduated, or had a leave of absence an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 3 instances where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2025. Questioned Costs None Context A total of 10 students who were credited with Federal Direct Loan Program proceeds that either withdrew, graduate, or had a leave of absence during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 3 of the students with Federal Direct Loan Program proceeds credited to their account that either withdrew, graduated, or had a leave of absence did not have the required exit counseling documented. Identification as a repeat finding This finding is a repeat finding (see prior year finding number: 2024-001). Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that exit conferencing has been properly documented. Two of the findings in the current fiscal 2025 occurred prior to the May revision by the Institute of its procedures. The third finding occurred during a period that the independent party performing the review function was on leave due to a death in the family. The Institute recognizes the importance of ensuring that exit conferences are performed timely and properly documented. Management has met with its staff involved in this process to emphasize its importance. Additionally, an additional staff member has been assigned to perform the review procedures if the staff member responsible is not available to timely perform the procedures.
Show full finding ▾Hide full finding ▴Finding 2025-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K263382 2025 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), for students who withdrew, graduated, or had a leave of absence an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 3 instances where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2025. Questioned Costs None Context A total of 10 students who were credited with Federal Direct Loan Program proceeds that either withdrew, graduate, or had a leave of absence during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 3 of the students with Federal Direct Loan Program proceeds credited to their account that either withdrew, graduated, or had a leave of absence did not have the required exit counseling documented. Identification as a repeat finding This finding is a repeat finding (see prior year finding number: 2024-001). Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that exit conferencing has been properly documented. Two of the findings in the current fiscal 2025 occurred prior to the May revision by the Institute of its procedures. The third finding occurred during a period that the independent party performing the review function was on leave due to a death in the family. The Institute recognizes the importance of ensuring that exit conferences are performed timely and properly documented. Management has met with its staff involved in this process to emphasize its importance. Additionally, an additional staff member has been assigned to perform the review procedures if the staff member responsible is not available to timely perform the procedures.
As reported in the Institutes fiscal 2024 Corrective Action Plan, in May 2025, the Institute revised its current procedures to include having an employee independent from the exit conference process review that any student not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that exit conferencing has been properly documented. Two of the findings in the current fiscal 2025 occurred prior to the May revision by the Institute of its procedures. The third finding occurred during a period that the independent party performing the review function was on leave due to a death in the family. The Institute recognizes the importance of ensuring that exit conferences are performed timely and properly documented. Management has met with its staff involved in this process to emphasize its importance. Additionally, an additional staff member has been assigned to perform the review procedures if the staff member responsible is not available to timely perform the procedures.
2024-001
Finding 2025-002 - Special Tests and Provisions – Disbursements on Behalf of Students - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P253382 2025 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 668.164 (h)(2)), A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than; i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition We noted 1 instance where the Institute did not return a credit balances regarding the Federal Pell Grant Program within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs None Context A total of 30 students who were credited with Federal Pell Grant Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Pell Grant Program proceeds credited to their account did not have credit balances refunded within the prescribed timeframes. Identification as a repeat finding This is not a repeat finding. Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure credit balances regarding Federal Pell Grant Program proceeds are refunded within the prescribed timeframes. Views of Responsible Officials In May of 2026, the Institute amended its procedures to (1) require the printing of a schedule of student balances after application of Federal Pell Grant and Loan receipts and (2) for all students with a credit balance within 12 days of the Pell receipt indicating the check number and date of the refund to the student on this schedule. This schedule is then to be reviewed for adherence to the required 14-day refund requirement under the Pell program by another staff member.
Show full finding ▾Hide full finding ▴Finding 2025-002 - Special Tests and Provisions – Disbursements on Behalf of Students - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P253382 2025 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 668.164 (h)(2)), A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than; i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition We noted 1 instance where the Institute did not return a credit balances regarding the Federal Pell Grant Program within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs None Context A total of 30 students who were credited with Federal Pell Grant Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Pell Grant Program proceeds credited to their account did not have credit balances refunded within the prescribed timeframes. Identification as a repeat finding This is not a repeat finding. Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure credit balances regarding Federal Pell Grant Program proceeds are refunded within the prescribed timeframes. Views of Responsible Officials In May of 2026, the Institute amended its procedures to (1) require the printing of a schedule of student balances after application of Federal Pell Grant and Loan receipts and (2) for all students with a credit balance within 12 days of the Pell receipt indicating the check number and date of the refund to the student on this schedule. This schedule is then to be reviewed for adherence to the required 14-day refund requirement under the Pell program by another staff member.
In May of 2026, the Institute amended its procedures to (1) require the printing of a schedule of student balances after application of Federal Pell Grant and Loan receipts and (2) for all students with a credit balance within 12 days of the Pell receipt indicating the check number and date of the refund to the student on this schedule. This schedule is then to be reviewed for adherence to the required 14-day refund requirement under the Pell program by another staff member.
FAC accepted this audit on June 17, 2025 — management decision was due December 17, 2025.
Section III - Federal Awards Findings and Questioned Costs Finding 2024-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 1 instance where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2024. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account did not have the required exit counseling documented. Identification as a repeat finding This finding is not a repeat finding. Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.
Show full finding ▾Hide full finding ▴Section III - Federal Awards Findings and Questioned Costs Finding 2024-001 - Special Tests and Provisions - Exit Counseling - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 1 instance where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The Institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2024. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the haphazardly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account did not have the required exit counseling documented. Identification as a repeat finding This finding is not a repeat finding. Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.
Finding 2024-001 – Special Tests and Provisions – Exit Counseling – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to document the exit conference of one student borrower in the Federal Direct Loans Program, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all exit conferences are documented. Under the revised procedures, an employee independent from the exit conference process is to review that any student that has not enrolled in a new semester or that is enrolled at less than half time status has received proper exit conferencing and that the exit conferencing has been properly documented.
Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted 1 instance where the Institute did not send out the required notifications regarding Federal Direct Student Loan Program proceeds that had been credited to participating student's accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account were not provided with the required notifications. Identification as a repeat finding Yes 2022-005 Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Views of Responsible Officials The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.
Show full finding ▾Hide full finding ▴Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification - Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted 1 instance where the Institute did not send out the required notifications regarding Federal Direct Student Loan Program proceeds that had been credited to participating student's accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause There was an administrative oversight that caused the above mentioned condition. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs None Context A total of 36 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that 1 of the students with Federal Direct Loan Program proceeds credited to their account were not provided with the required notifications. Identification as a repeat finding Yes 2022-005 Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Views of Responsible Officials The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.
Finding 2024-002 - Special Tests and Provisions - Federal Direct Loan Program Student Notification – Significant Deficiency Name of Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K243382 2024 Name of Pass-through Entity: N/A Planned Corrective Action: The failure to timely send out the required notification of Federal Direct Student Loan Program proceeds credited to one student’s account, as noted in the auditor’s findings, was an administrative oversight. In May 2025, the Institute reviewed and revised its current procedures to ensure that all required notifications are made. Under the revised procedures, an employee independent from the student loan proceed crediting notification process is to review that notifications are sent out within prescribed time frames in accordance with U.S. Department of Education regulations to all students receiving and being credited with Federal Direct Loan Program amounts and that copies of the notifications are maintained in each applicable student’s file.
2022-005
FAC accepted this audit on June 25, 2024 — management decision was due December 25, 2024.
Item 2023-001 Federal Direct Loan Program Student Notification (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted that the Institute did not send out the required notifications regarding Federal Direct Loan Program proceeds that had been credited to participating students' accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs - None Context A total of 37 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that in the Fall and Spring semesters none of the students with Federal Direct Loan Program proceeds credited to their account were provided with the required notifications. Identification as a Repeat Finding - Yes, repeating finding of 2022-005 Recommendation We recommended in the prior year for the Institute to review and revise its procedures and to put controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students timely. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. In the Summer 2023 semester, a system was implemented to send out the required notifications regarding Federal Direct Loan Program proceeds that have been applied to a participating student's account.
Show full finding ▾Hide full finding ▴Item 2023-001 Federal Direct Loan Program Student Notification (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted that the Institute did not send out the required notifications regarding Federal Direct Loan Program proceeds that had been credited to participating students' accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs - None Context A total of 37 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that in the Fall and Spring semesters none of the students with Federal Direct Loan Program proceeds credited to their account were provided with the required notifications. Identification as a Repeat Finding - Yes, repeating finding of 2022-005 Recommendation We recommended in the prior year for the Institute to review and revise its procedures and to put controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students timely. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. In the Summer 2023 semester, a system was implemented to send out the required notifications regarding Federal Direct Loan Program proceeds that have been applied to a participating student's account.
May 7, 2024 U.S. Department of Education American Academy McAllister Institute of Funeral Services, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2023. Auditors: CohnReznick 1301 Avenue of the Americas New York, NY 10019 Audit period: October 1, 2022 to September 30, 2023 The findings from the fiscal year 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT SIGNIFICANT DEFICIENCY 2023-001 Federal Direct Loan Program Student Recommendation: We recommended in the prior year that the Institute review and revise its procedures to put controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to par-ticipating students. Action Plan: We agree with both the finding and the recommendation. In the Summer 2023 semester, a system was implemented to send out the required notifications regarding Federal Direct Loan Program proceeds that have been applied to a participating student's account. If the U.S. Department of Education has questions regarding this plan, please call Robert Graber at 732-547-9549.
2022-005
FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.
Finding 2022-001: Schedule of Federal Awards (Material Weakness) U.S. Department of Education COVID-19 Education Stabilization Fund 84.425E, 84.425F Compliance requirement: Reporting Criteria: The Uniform Guidance requires that the auditee prepare a Schedule of Federal Awards ("SEFA") for the period covered by the auditee's financial statements. The schedule shall provide the total federal awards expended for each individual Federal program and the Assistance Listing number or other identifying number when the Assistance Listing Number information is not available. Condition and Context: During our audit, we noted that the Higher Education Emergency Relief Funds ("HEERF") expended per the SEFA in the Uniform Guidance report and submitted to the Federal Audit Clearinghouse for the year ended September 30, 2021, were not properly recorded. The actual HEERF expended for the year ended September 30, 2021, was $97,066 compared to the HEERF expenditures reflected on the SEFA of $440,450. This resulted in an inaccurate SEFA being submitted to the Federal Audit Clearinghouse and the Department of Education. Cause: Internal controls over the accurate preparation and completeness of the SEFA were not operating effectively. Effect or Potential Effect: The institute was not in compliance with federal regulations regarding reporting for the year ended September 30, 2021. An improper SEFA could result in errors in accounting, revenue recognition, and disallowed costs. Questioned costs: $0 Identification of repeat finding: No. Recommendation: We recommend that the Institute implement a formal policy for preparing the SEFA and reconciling the SEFA for accuracy and completeness to underlying accounting records. View of Responsible Officials: We agree with both the finding and the recommendation. The amount reflected in the year ended September 30,2021 SEFA was misstated due to an incorrect interpretation as to the amount to be reported as an accrual of HEERF expenditures under the Uniform Guidance for SEFA reporting. The correct amount of HEERF expenditures were included in the GAAP financial year ended September 30, 2021 financial statements. HERRF expenditures for the year ended September 30,2022 were reported correctly in both the SEFA report and the GAAP financial statements.
Show full finding ▾Hide full finding ▴Finding 2022-001: Schedule of Federal Awards (Material Weakness) U.S. Department of Education COVID-19 Education Stabilization Fund 84.425E, 84.425F Compliance requirement: Reporting Criteria: The Uniform Guidance requires that the auditee prepare a Schedule of Federal Awards ("SEFA") for the period covered by the auditee's financial statements. The schedule shall provide the total federal awards expended for each individual Federal program and the Assistance Listing number or other identifying number when the Assistance Listing Number information is not available. Condition and Context: During our audit, we noted that the Higher Education Emergency Relief Funds ("HEERF") expended per the SEFA in the Uniform Guidance report and submitted to the Federal Audit Clearinghouse for the year ended September 30, 2021, were not properly recorded. The actual HEERF expended for the year ended September 30, 2021, was $97,066 compared to the HEERF expenditures reflected on the SEFA of $440,450. This resulted in an inaccurate SEFA being submitted to the Federal Audit Clearinghouse and the Department of Education. Cause: Internal controls over the accurate preparation and completeness of the SEFA were not operating effectively. Effect or Potential Effect: The institute was not in compliance with federal regulations regarding reporting for the year ended September 30, 2021. An improper SEFA could result in errors in accounting, revenue recognition, and disallowed costs. Questioned costs: $0 Identification of repeat finding: No. Recommendation: We recommend that the Institute implement a formal policy for preparing the SEFA and reconciling the SEFA for accuracy and completeness to underlying accounting records. View of Responsible Officials: We agree with both the finding and the recommendation. The amount reflected in the year ended September 30,2021 SEFA was misstated due to an incorrect interpretation as to the amount to be reported as an accrual of HEERF expenditures under the Uniform Guidance for SEFA reporting. The correct amount of HEERF expenditures were included in the GAAP financial year ended September 30, 2021 financial statements. HERRF expenditures for the year ended September 30,2022 were reported correctly in both the SEFA report and the GAAP financial statements.
Recommendation: The auditors recommended that the Institute implement a formal policy for preparing the SEFA and reconciling the SEFA for accuracy and completeness to underlying accounting records. Action Taken: We agree with both the finding and the recommendation. The amount reflected in the year ended September 30,2021 SEFA was misstated due to an incorrect interpretation as to the amount to be reported as an accrual of HEERF expenditures under the Uniform Guidance for SEFA reporting. The correct amount of HEERF expenditures were included in the GAAP financial year ended September 30,2021 financial statements. HERRF expenditures for the year ended September 30,2022 were reported correctly in both the SEFA report and the GAAP financial statements.
Finding 2022-002: Earmarking (Significant Deficiency) U.S. Department of Education COVID-19 Education Stabilization Fund 84.425E, 84.425F Compliance requirement: Earmarking Criteria: The American Rescue Plan created two new requirements that a portion of HEERF III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to recent unemployment of a family member or independent student, or other circumstances described in section 479A of the Higher Education Act. Institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition and Context: During our audit procedures we noted that the entire Institutional amount awarded under ARP HEERF III was used to discharge student debt. The organization failed to earmark a portion of the award toward the two required uses. Cause: These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect: The institute was not in compliance with federal regulations regarding earmarking for the year ended September 30, 2022. Questioned costs: $0 Identification of repeat finding: No. Recommendation: We recommend that the Institute add additional procedures and implement controls to ensure that they are complying with earmarking requirements. View of Responsible Officials: We agree with both the finding and the recommendation. Procedures have been implemented to ensure that a portion of HEERF III institutional funds are used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines for the remaining ARP HEERF III award balance and that proper documentation of the funds used is maintained. The following should be noted: a) Approximately 85% of AAMI?s students attend only the school?s on- line program and no mitigation by AAMI for these students was required. b) AAMI moved into its new space which includes its classrooms in November 2020 after the start of the Coronavirus Epidemic. A review of the new space ventilation equipment, which was state of the art equipment, was performed and the ventilation system was determined to be very good and needed no enhancing. c) AAMI consistently purchased masks for students, staff and visitors. Efforts were increased to support a clean and sanitary campus through the purchase of hand sanitizer. Our office expenses increased over $100,000 from 2021 to 2022, not all of which was due to COVID-19 prevention; however, the increase in our cleaning expense which is part of that demonstrates our commitment to consistent cleaning and disinfection. d) Campus class sizes were monitored closely during the pandemic. Although AAMI did not have to alter class sizes due to standard enrollment, AAMI did require classroom occupancy to be reduced so social distancing protocols could be followed. e) Fortunately, all AAMI staff members were vaccinated prior to HEERF III; however, all staff members were urged to work remotely if they had any respiratory illness symptoms. We also provided students with the opportunity to obtain excused absences if respiratory illness treatment could be documented by a doctor. Instructors were advised to use remote learning tools for students who were unable to attend campus due to illness. Additionally, a direct outreach to financial aid applicants about the opportunity to receive financial aid adjustment due to recent unemployment of a family member or being an independent student will be performed.
Show full finding ▾Hide full finding ▴Finding 2022-002: Earmarking (Significant Deficiency) U.S. Department of Education COVID-19 Education Stabilization Fund 84.425E, 84.425F Compliance requirement: Earmarking Criteria: The American Rescue Plan created two new requirements that a portion of HEERF III institutional funds must be used (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to recent unemployment of a family member or independent student, or other circumstances described in section 479A of the Higher Education Act. Institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition and Context: During our audit procedures we noted that the entire Institutional amount awarded under ARP HEERF III was used to discharge student debt. The organization failed to earmark a portion of the award toward the two required uses. Cause: These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect: The institute was not in compliance with federal regulations regarding earmarking for the year ended September 30, 2022. Questioned costs: $0 Identification of repeat finding: No. Recommendation: We recommend that the Institute add additional procedures and implement controls to ensure that they are complying with earmarking requirements. View of Responsible Officials: We agree with both the finding and the recommendation. Procedures have been implemented to ensure that a portion of HEERF III institutional funds are used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines for the remaining ARP HEERF III award balance and that proper documentation of the funds used is maintained. The following should be noted: a) Approximately 85% of AAMI?s students attend only the school?s on- line program and no mitigation by AAMI for these students was required. b) AAMI moved into its new space which includes its classrooms in November 2020 after the start of the Coronavirus Epidemic. A review of the new space ventilation equipment, which was state of the art equipment, was performed and the ventilation system was determined to be very good and needed no enhancing. c) AAMI consistently purchased masks for students, staff and visitors. Efforts were increased to support a clean and sanitary campus through the purchase of hand sanitizer. Our office expenses increased over $100,000 from 2021 to 2022, not all of which was due to COVID-19 prevention; however, the increase in our cleaning expense which is part of that demonstrates our commitment to consistent cleaning and disinfection. d) Campus class sizes were monitored closely during the pandemic. Although AAMI did not have to alter class sizes due to standard enrollment, AAMI did require classroom occupancy to be reduced so social distancing protocols could be followed. e) Fortunately, all AAMI staff members were vaccinated prior to HEERF III; however, all staff members were urged to work remotely if they had any respiratory illness symptoms. We also provided students with the opportunity to obtain excused absences if respiratory illness treatment could be documented by a doctor. Instructors were advised to use remote learning tools for students who were unable to attend campus due to illness. Additionally, a direct outreach to financial aid applicants about the opportunity to receive financial aid adjustment due to recent unemployment of a family member or being an independent student will be performed.
Recommendation: The auditors recommended that the Institute add additional procedures and implement controls to ensure that they are complying with earmarking requirements. Action Taken: We agree with both the finding and the recommendation. Procedures have been implemented to ensure that a portion of HEERF III institutional funds are used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines for the remaining ARP HEERF III award balance and that proper documentation of the funds used is maintained.
Item 2022-003 Exit Counseling (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 16 instances where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect: The institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2022. Questioned Costs - None Context Of the 28 participating students subject to exit counseling included in the 40 randomly selected sample of participating students, exit counseling was not documented for 16 participating students. Identification as a repeat finding - No Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. The instances of missed exit conferences with borrowers under the Federal Direct Loan Program were primarily related to students who had been dropped due to non-payment of tuition and who did not respond to our attempts to contact them for an exit conference. We understand that we failed to properly document our efforts to contact these students to schedule and perform an exit conference. We have amended our procedures to document our efforts to contact any students for which an exit conference is required and we have not been able to schedule one.
Show full finding ▾Hide full finding ▴Item 2022-003 Exit Counseling (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 685.304 (b) (1)), an institution must ensure exit counseling is conducted with each Federal Direct Loans Program borrower and the institution must maintain in the student borrower's file documents substantiating compliance with these requirements (34 CFR 685.304 (b)(7)). Condition We noted 16 instances where the Institute failed to document exit counseling which should have been conducted with a participating student during the award year. Cause These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect: The institute was not in compliance with federal regulations regarding special tests and provisions for the year ended September 30, 2022. Questioned Costs - None Context Of the 28 participating students subject to exit counseling included in the 40 randomly selected sample of participating students, exit counseling was not documented for 16 participating students. Identification as a repeat finding - No Recommendation We recommend the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. The instances of missed exit conferences with borrowers under the Federal Direct Loan Program were primarily related to students who had been dropped due to non-payment of tuition and who did not respond to our attempts to contact them for an exit conference. We understand that we failed to properly document our efforts to contact these students to schedule and perform an exit conference. We have amended our procedures to document our efforts to contact any students for which an exit conference is required and we have not been able to schedule one.
Recommendation: The auditors recommended that the Institute continue its efforts to ensure all required exit counseling procedures are conducted and documented in compliance with U.S. Department of Education regulations. Action Taken: We agree with both the finding and the recommendation. The instances of missed exit conferences with borrowers under the Federal Direct Loan Program were primarily related to students who had been dropped due to non-payment of tuition and who did not respond to our attempts to contact them for an exit conference. We understand that we failed to properly document our efforts to contact these students to schedule and perform an exit conference. We have amended our procedures to document our efforts to contact any students for which an exit conference is required and we have not been able to schedule one.
Item 2022-004 Enrollment Reporting (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 685.309 (b)), an institution is required to report a participating student's enrollment status on the Enrollment Reporting roster file in a timely manner as prescribed by U.S. Department of Education regulations. Condition We noted 2 instances where the enrollment status of a participating student in an applicable Title IV program was not reported in a timely manner. Cause These findings appear to be due to administrative oversights. Effect or Potential Effect: The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs - None Context Of the 40 randomly selected sample of participating students, the enrollment status was not reported in a timely manner for 2 students. Identification as a repeat finding - No Recommendation We recommend that the Institute review and revise, if necessary, its current procedures and have controls in place to ensure that participating student's enrollment status on the Enrollment Reporting roster file via the National Student Loan Data System is reported in a timely manner as prescribed by U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. A system has been implemented to ensure that the National Student Loan Data system is updated on a timely basis as prescribed by U.S. Department of Education regulations.
Show full finding ▾Hide full finding ▴Item 2022-004 Enrollment Reporting (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 685.309 (b)), an institution is required to report a participating student's enrollment status on the Enrollment Reporting roster file in a timely manner as prescribed by U.S. Department of Education regulations. Condition We noted 2 instances where the enrollment status of a participating student in an applicable Title IV program was not reported in a timely manner. Cause These findings appear to be due to administrative oversights. Effect or Potential Effect: The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs - None Context Of the 40 randomly selected sample of participating students, the enrollment status was not reported in a timely manner for 2 students. Identification as a repeat finding - No Recommendation We recommend that the Institute review and revise, if necessary, its current procedures and have controls in place to ensure that participating student's enrollment status on the Enrollment Reporting roster file via the National Student Loan Data System is reported in a timely manner as prescribed by U.S. Department of Education regulations. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. A system has been implemented to ensure that the National Student Loan Data system is updated on a timely basis as prescribed by U.S. Department of Education regulations.
Recommendation: The auditors recommended that the Institute review and revise, if necessary, its current procedures and have controls in place to ensure that participating student's enrollment status on the Enrollment Reporting roster file via the Na-tional Student Loan Data System is reported in a timely manner as prescribed by U.S. Department of Education regulations. Action Taken: We agree with both the finding and the recommendation. A system has been imple-mented to ensure that the National Student Loan Data system is updated on a timely basis as pre-scribed by U.S. Department of Education regula-tions.
Item 2022-005 Federal Direct Loan Program Student Notification (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted that the Institute did not send out the required notifications regarding Federal Direct Student Loan Program proceeds that had been credited to participating student's accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect: The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs - None Context A total of 37 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that none of the students with Federal Direct Loan Program proceeds credited to their account were provided with the required notifications. Identification as a repeat finding - No Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. A system has been implemented to send out the required notifications regarding Federal Direct Student Loan Program proceeds that have been applied to a participating student?s account.
Show full finding ▾Hide full finding ▴Item 2022-005 Federal Direct Loan Program Student Notification (Significant Deficiency) U.S. Department of Education Federal Direct Student Loans (Assistance Listing Number # 84.268) Compliance requirement: Special Tests and Provisions Criteria According to the Federal Register (34 CFR 668.165 (a)(3)), an institution must provide notice to a participating student no earlier than 30 days before, and no later than seven days after, crediting the student's account with Federal Direct Loan Program proceeds at the institution, if the institution does not receive affirmative confirmation from the student. Condition We noted that the Institute did not send out the required notifications regarding Federal Direct Student Loan Program proceeds that had been credited to participating student's accounts within prescribed timeframes in accordance with U.S. Department of Education regulations. Cause These findings appear to be due to a deficiency in internal controls. Effect or Potential Effect: The effect of these findings is noncompliance with U.S. Department of Education regulations regarding special tests and provisions. Questioned Costs - None Context A total of 37 students who were credited with Federal Direct Loan Program proceeds during the year were included in the randomly selected sample of 40 participating students. Our testing noted that none of the students with Federal Direct Loan Program proceeds credited to their account were provided with the required notifications. Identification as a repeat finding - No Recommendation We recommend the Institute review and revise, its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Views of Responsible Officials and Planned Corrective Actions We agree with both the finding and the recommendation. A system has been implemented to send out the required notifications regarding Federal Direct Student Loan Program proceeds that have been applied to a participating student?s account.
Recommendation: The auditors recommended that the Institute review and revise its current procedures and have controls in place to ensure required notifications regarding Federal Direct Loan Program proceeds are provided to participating students. Action Plan: We agree with both the finding and the recommendation. A system has been implemented to send out the required notifications regarding Federal Direct Student Loan Program proceeds that have been applied to a participating student?s ac-count.
FAC accepted this audit on March 3, 2021 — management decision was due September 3, 2021.
Reconciliation of Direct Loan funds was not documented and reconciliation of disbursement records was not performed. Criteria: 34 CFR ?685.300(b)(5) (Regulations of the Department of Education) requires that Direct Loan funds and disbursement records be reconciled to institutional records on a monthly basis. Cause: AAMI believed that, due to its small size, the use of third party software, and the timing of its drawdown schedule, it was not required to perform monthly reconciliations. Effect: Noncompliance with statutory requirements may cause incorrect student loan data to remain undetected. It may also negatively impact AAMI?s ability to continue participating in the Direct Loan Program. Recommendation: Document monthly reconciliations of Direct Loan funds. Perform and document monthly reconciliation of disbursement records. Views of Responsible Officials and Planned Corrective Actions: AAMI believes that it does maintain its Direct Loan funds and disbursements in satisfactory order. Reconciliation of the Direct Loan funds is performed on a monthly basis even though it is not documented. AAMI?s small staff provides us easy access to one another so that we may communicate thoroughly and effectively when changes to procedures as required by new compliance requirements. This has also allowed the small staff to better observe the Direct Loan funds and disbursements. AAMI has highly trained and skilled employees who have been with the organization for many years. These individuals have maintained the high standards that AAMI believes in. In order to ensure adherence to federal regulations AAMI will create documentation that monthly Direct Loan funds are reconciled.
Show full finding ▾Hide full finding ▴Condition: Reconciliation of Direct Loan funds was not documented and reconciliation of disbursement records was not performed. Criteria: 34 CFR ?685.300(b)(5) (Regulations of the Department of Education) requires that Direct Loan funds and disbursement records be reconciled to institutional records on a monthly basis. Cause: AAMI believed that, due to its small size, the use of third party software, and the timing of its drawdown schedule, it was not required to perform monthly reconciliations. Effect: Noncompliance with statutory requirements may cause incorrect student loan data to remain undetected. It may also negatively impact AAMI?s ability to continue participating in the Direct Loan Program. Recommendation: Document monthly reconciliations of Direct Loan funds. Perform and document monthly reconciliation of disbursement records. Views of Responsible Officials and Planned Corrective Actions: AAMI believes that it does maintain its Direct Loan funds and disbursements in satisfactory order. Reconciliation of the Direct Loan funds is performed on a monthly basis even though it is not documented. AAMI?s small staff provides us easy access to one another so that we may communicate thoroughly and effectively when changes to procedures as required by new compliance requirements. This has also allowed the small staff to better observe the Direct Loan funds and disbursements. AAMI has highly trained and skilled employees who have been with the organization for many years. These individuals have maintained the high standards that AAMI believes in. In order to ensure adherence to federal regulations AAMI will create documentation that monthly Direct Loan funds are reconciled.
Finding: Reconciliation of Direct Loan funds was not documented and reconciliation of disbursement records was not performed. Questioned Costs: None Status: In progress Recommendation: Document monthly reconciliations of Direct Loan funds. Perform and document monthly reconciliation of disbursement records. Corrective Action: AAMI believes that it does maintain its Direct Loan funds and disbursements in satisfactory order. Reconciliation of the Direct Loan funds is performed on a monthly basis even though it is not documented. AAMI?s small staff provides us easy access to one another so that we may communicate thoroughly and effectively when changes to procedures as required by new compliance requirements. This has also allowed the small staff to better observe the Direct Loan funds and disbursements. AAMI has highly trained and skilled employees who have been with the organization for many years. These individuals have maintained the high standards that AAMI believes in. In order to ensure adherence to federal regulations AAMI will create documentation that monthly Direct Loan funds are reconciled. Anticipated Completion Date: Estimated May 2021 Contact: Tracy Lentz, Director of Operations
AAMI does not have written policies and procedures for finance or for financial aid. Criteria: Compliance requirements for Activities Allowed or Unallowed state that the organization must have written polices and control procedures for costs coded to federal awards for Pell and Direct Loans. Compliance requirements for Cash Management require written procedures to implement the requirements of 2 CFR ?200.305 for Pell and Direct Loans. Compliance requirements for Special Tests and Provisions require a written quality assurance process for Direct Loans. Cause: AAMI believed that the documentation requirements did not apply to them because of their small size. Due to the small size of the finance and financial aid departments and their low employee turnover, AAMI did not deem it cost-beneficial to document its policies and procedures. Effect: Undocumented policies and procedures increase the risk of errors and omissions when new employees are hired or current employees take on new responsibilities. Noncompliance with Uniform Guidance requirements may also negatively impact AAMI?s ability to continue participating in the Pell Grant and Direct Loan Programs. Recommendation: Create a manual for finance and financial aid that documents current policies and procedures. Manual should also incorporate new policies and procedures, as necessary, to comply with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: AAMI believes that it has created a strong set of policies and procedures regarding Finance and Financial Aid. AAMI has multiple references to these policies and procedures in their current catalog and on their website. Both of these can be found at the following url www.funeraleducation.org. AAMI constantly updates these policies and procedures in order to maintain compliance with Federal regulations. As reiterated from Finding #1, AAMI?s small staff provides us easy access to one another so that we may communicate thoroughly and effectively when changes to procedures as required by new compliance requirements. These individuals have worked together for many years without complications. Their effectiveness as a team is well noted within the organization and therefore a written manual of procedures felt unnecessary. In order to ensure adherence to federal regulations and assist with future needs for staff training, AAMI is working with consultants on developing a written manual to supplement the policies and procedures referenced in the catalog.
Show full finding ▾Hide full finding ▴Condition: AAMI does not have written policies and procedures for finance or for financial aid. Criteria: Compliance requirements for Activities Allowed or Unallowed state that the organization must have written polices and control procedures for costs coded to federal awards for Pell and Direct Loans. Compliance requirements for Cash Management require written procedures to implement the requirements of 2 CFR ?200.305 for Pell and Direct Loans. Compliance requirements for Special Tests and Provisions require a written quality assurance process for Direct Loans. Cause: AAMI believed that the documentation requirements did not apply to them because of their small size. Due to the small size of the finance and financial aid departments and their low employee turnover, AAMI did not deem it cost-beneficial to document its policies and procedures. Effect: Undocumented policies and procedures increase the risk of errors and omissions when new employees are hired or current employees take on new responsibilities. Noncompliance with Uniform Guidance requirements may also negatively impact AAMI?s ability to continue participating in the Pell Grant and Direct Loan Programs. Recommendation: Create a manual for finance and financial aid that documents current policies and procedures. Manual should also incorporate new policies and procedures, as necessary, to comply with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions: AAMI believes that it has created a strong set of policies and procedures regarding Finance and Financial Aid. AAMI has multiple references to these policies and procedures in their current catalog and on their website. Both of these can be found at the following url www.funeraleducation.org. AAMI constantly updates these policies and procedures in order to maintain compliance with Federal regulations. As reiterated from Finding #1, AAMI?s small staff provides us easy access to one another so that we may communicate thoroughly and effectively when changes to procedures as required by new compliance requirements. These individuals have worked together for many years without complications. Their effectiveness as a team is well noted within the organization and therefore a written manual of procedures felt unnecessary. In order to ensure adherence to federal regulations and assist with future needs for staff training, AAMI is working with consultants on developing a written manual to supplement the policies and procedures referenced in the catalog.
Finding: AAMI does not have written policies and procedures for finance and for financial aid. Questioned Costs: None Status: In progress Recommendation: Create a manual for finance and financial aid that documents current policies and procedures. The manual should also incorporate new policies and procedures, as necessary, to comply with Uniform Guidance requirements. Corrective Action: AAMI believes that it has created a strong set of policies and procedures regarding Finance and Financial Aid. AAMI has multiple references to these policies and procedures in their current catalog and on their website. Both of these can be found on the website at www.funeraleducation.org. AAMI constantly updates these policies and procedures in order to maintain compliance with Federal regulations. As reiterated from Finding #1, AAMI?s small staff provides us easy access to one another so that we may communicate thoroughly and effectively when changes to procedures as required by new compliance requirements. These individuals have worked together for many years without complications. Their effectiveness as a team is well noted within the organization and therefore a written manual of procedures felt unnecessary. In order to ensure adherence to federal regulations and assist with future needs for staff training, AAMI is working with consultants on developing a written manual to supplement the policies and procedures referenced in the catalog. Anticipated Completion Date: Estimated May 2021 Contact: Tracy Lentz, Director of Operations
FAC accepted this audit on February 25, 2020 — management decision was due August 25, 2020.
The Institute did not conduct employee training in accordance with the Gramm-Leach-Bliley Act. Criteria: Federal regulation requires that the Institute conduct employee training. Cause: Due to the change in staff over the years, the training program was not maintained. Effect: Some employees might not have sufficient knowledge of the requirements under this act. Recommendation: The Institute should institute an employee training program. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and the recommendation has been implemented.
Show full finding ▾Hide full finding ▴Condition: The Institute did not conduct employee training in accordance with the Gramm-Leach-Bliley Act. Criteria: Federal regulation requires that the Institute conduct employee training. Cause: Due to the change in staff over the years, the training program was not maintained. Effect: Some employees might not have sufficient knowledge of the requirements under this act. Recommendation: The Institute should institute an employee training program. Views of Responsible Officials and Planned Corrective Actions: The Institute agrees with the finding and the recommendation has been implemented.
U.S. Department of Education American Academy McAllister Institute of Funeral Service, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2019. Independent public accounting firm: Buchbinder Tunick & Company LLP, One Pennsylvania Plaza, Suite 3500, New York, NY 10019 Audit period: Year ended September 30, 2019 The findings from the September 30, 2019 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Federal Award Program Audits U.S. Department of Education 2019-001 Recommendation: We recommend that the Institute implement an employee training program in order to comply with the Gramm-Leach-Bliley Act. Corrective Action Taken: We concur with the recommendation, and it was implemented effective January 28, 2020. If the U.S. Department of Education has questions regarding this plan, please contact Tracy Lentz. Sincerely yours, President
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