EIN: 222797398
UEI: E4UZBXLPA2V3
Audited by: GRANT THORNTON LLP
Cognizant agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 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 August 24, 2026 (6 days ago).
What is a management decision? →Institutions are responsible for accurately reporting all Campus-Level Record data elements and one of the Campus-Level Record data elements which ED considers to be high risk is the “Enrollment Effective Date”. Enrollment Effective Date is the date that the current enrollment status reported for a student was first effective. For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. Additionally, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Cause: Lack of precision in the review of reporting of Enrollment Effective Dates to the NSLDS as well as the review of the consistency of information between NSLDS and the College’s internal records, before submission. Effect: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, the effective date per internal College records did not match NSLDS. Questioned Costs: None. Context: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. This student was noted per the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately as Program-Level Enrollment data indicated this student as being withdrawn but the Campus-Level Enrollment data did not. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was followed, but the Date per College records did not match that of NSLDS. Repeat Finding: No. Recommendation: It is recommended that the College enhances the precision of its review of both categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types which are accurate and do not contradict each other. Views of Responsible Officials: In response, the College implemented standardized processes for processing LOA and withdrawal actions. This documentation provides a framework for staff to ensure that effective dates per the College are aligned with what is transmitted to the NSLDS. Additionally, the College revised its reporting schedule to ensure that LOA and withdrawal updates are transmitted on a regular, recurring basis. Refer to the Corrective Action Plan for Current Year Findings.
Show full finding ▾Hide full finding ▴Finding 2025-001: Special Tests and Provisions – NSLDS Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition: Institutions are responsible for accurately reporting all Campus-Level Record data elements and one of the Campus-Level Record data elements which ED considers to be high risk is the “Enrollment Effective Date”. Enrollment Effective Date is the date that the current enrollment status reported for a student was first effective. For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. Additionally, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Cause: Lack of precision in the review of reporting of Enrollment Effective Dates to the NSLDS as well as the review of the consistency of information between NSLDS and the College’s internal records, before submission. Effect: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, the effective date per internal College records did not match NSLDS. Questioned Costs: None. Context: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. This student was noted per the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately as Program-Level Enrollment data indicated this student as being withdrawn but the Campus-Level Enrollment data did not. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was followed, but the Date per College records did not match that of NSLDS. Repeat Finding: No. Recommendation: It is recommended that the College enhances the precision of its review of both categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types which are accurate and do not contradict each other. Views of Responsible Officials: In response, the College implemented standardized processes for processing LOA and withdrawal actions. This documentation provides a framework for staff to ensure that effective dates per the College are aligned with what is transmitted to the NSLDS. Additionally, the College revised its reporting schedule to ensure that LOA and withdrawal updates are transmitted on a regular, recurring basis. Refer to the Corrective Action Plan for Current Year Findings.
Finding 2025-001: Special Tests and Provisions – NSLDS Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Responsible Persons: Heba Jahama, Director of Records and Registration, 609-771-2376, Billy Peitz, Associate Director of Records, Reporting, and Enrollment, 609-771-2333 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College had 1 student out of an initial sample of 40, for which it was noted that the enrollment effective date was reported by the College to the NSLDS inaccurately. The student was noted by the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately. Program-Level Enrollment data indicated this student as being withdrawn, but the Campus-Level Enrollment data did not. Additionally, 2 students out of an additional sample of 40 tested were found to have not followed the internal College policy for determining the enrollment effective date, despite internal College records matching those of the NSLDS. Lastly, for 1 out of the additional 40 students, the effective date per internal College records did not match NSLDS. The College recognizes the importance of ensuring accurate enrollment data regarding NSLDS reporting under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. After a thorough review of the data errors, it was determined that the root cause was a lack of standardized business processes for LOA and Withdrawal actions. We have since implemented several corrective actions to ensure data integrity and institutional consistency. New procedural documentation has been established to clarify the standard operating procedure for LOAs and Withdrawals. This documentation provides a definitive framework for staff to ensure that term withdrawal dates within PAWS (the system of record) are perfectly aligned with program status updates transmitted to the National Student Clearinghouse (NSC). The updated operating procedures have been shared with all relevant personnel to ensure that staff members are proficient in the new PAWS-to-NSC alignment protocols. In addition, the College has noted that the date of record for student registration must serve as the primary trigger for external reporting. This eliminates inconsistencies between the date a student initiates a withdrawal and the date reported to external agencies. To mitigate the risk of reporting lags, the College has revised its reporting schedule. LOA and Withdrawal updates are now transmitted to the Clearinghouse on a regular, recurring basis, independent of the standard comprehensive enrollment file processing cycle. This ensures that student status changes are reflected in the NSC database timely. The College implemented the corrective action on 12/16/2025. Anticipated Completion Date: Completed in December 2025, with ongoing monitoring
For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the initial calculation by the College of the student’s SAI. This was the result of a change in the student’s enrollment intensity which was not properly captured in the calculation of PELL aid. Cause: The College’s manual review of the PELL award calculation under the reprocessed FAFSA for this student was not precise enough to properly identify changes in the student’s enrollment intensity during the period as part of the calculation of the PELL award. Effect: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the initial calculation by the College of the student’s SAI. This was the result of a change in the student’s enrollment intensity which was not properly captured in the calculation of PELL aid. Questioned Costs: N/A Context: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the calculation by the College of the student’s SAI and enrollment intensity. The student was under-awarded PELL based on a change in enrollment intensity during the semester which was not accurately captured in the College’s reprocessing of the student ISIR form as part of the College’s implementation of the FAFSA Simplification Act. Repeat Finding: No. Recommendation: It is recommended that the College conduct a precise review of student enrollment intensity changes throughout the award disbursement process to ensure that they do not result in errors in the calculations and disbursement of aid. Views of Responsible Officials: In response, the College implemented further reporting enhancements to ensure that all awards are accurate. This includes generating the following reports for further review and analysis: all student actions following the Add/Drop period until mid-semester, Pell-only students who are less than full-time at the end of the Add/Drop period, and weekly student enrollment intensity changes. Refer to the Corrective Action Plan for Current Year Findings.
Show full finding ▾Hide full finding ▴Finding 2025-002: Eligibility Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Criteria: 34 CFR 668.42, 34 CFR 673.5, 34 CFR 673.6, and 34 CFR 685.301 require institutions to ensure that aid awarded to students does not exceed the student’s financial need or cost of attendance (COA). The determination of need-based award amounts is based on financial need. Financial need is defined as the student’s COA minus the student’s student aid index (“SAI”). In accordance with the FAFSA Simplification Act, which included a set of changes to the Free Application for Federal Student Aid (“FAFSA”) aimed at making the process easier and more accessible by reducing the number of questions and simplifying the financial aid calculation formula, the new SAI amount replaced the Expected Family Contribution (“EFC”). SAI is computed by the FAFSA processing system (“FPS”) and is included on the student’s FAFSA submission. To avoid any overpayments, need-based awards cannot exceed the student’s overall financial need. Condition: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the initial calculation by the College of the student’s SAI. This was the result of a change in the student’s enrollment intensity which was not properly captured in the calculation of PELL aid. Cause: The College’s manual review of the PELL award calculation under the reprocessed FAFSA for this student was not precise enough to properly identify changes in the student’s enrollment intensity during the period as part of the calculation of the PELL award. Effect: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the initial calculation by the College of the student’s SAI. This was the result of a change in the student’s enrollment intensity which was not properly captured in the calculation of PELL aid. Questioned Costs: N/A Context: For 1 out of 40 students selected for eligibility compliance and control testing, we identified that the student received the incorrect amount of PELL grant awards based on the calculation by the College of the student’s SAI and enrollment intensity. The student was under-awarded PELL based on a change in enrollment intensity during the semester which was not accurately captured in the College’s reprocessing of the student ISIR form as part of the College’s implementation of the FAFSA Simplification Act. Repeat Finding: No. Recommendation: It is recommended that the College conduct a precise review of student enrollment intensity changes throughout the award disbursement process to ensure that they do not result in errors in the calculations and disbursement of aid. Views of Responsible Officials: In response, the College implemented further reporting enhancements to ensure that all awards are accurate. This includes generating the following reports for further review and analysis: all student actions following the Add/Drop period until mid-semester, Pell-only students who are less than full-time at the end of the Add/Drop period, and weekly student enrollment intensity changes. Refer to the Corrective Action Plan for Current Year Findings.
Finding 2025-002: Eligibility Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid, 609-771-2211 Corrective Action Plan: During the compliance audit for the fiscal year ending June 30, 2025, the College had one student out of a sample of 40 who was selected for the eligibility compliance and control testing that had an incorrect Pell grant award for the Spring 2025 semester. The student was identified as having received the incorrect amount of Pell based on changes in enrollment intensity during the College’s Add/Drop period. The result of this error was that the student was under-awarded the Pell grant. Once the error was discovered, the student’s Pell grant was increased to the correct amount and reported to COD. The College recognizes the importance of reviewing student enrollment intensity changes throughout the disbursement process to ensure it does not result in errors in the calculation and disbursement of aid in accordance with 34 CFR 668.42, 34 CFR 673.5, 34 CFR 673.6, and 34 CFR 685.301. The College has a robust process for confirming enrollment intensity, which includes automated system reviews of student records, as well as manual/in-person award confirmations. In this student’s case, there were multiple course changes in a short span of time during the Spring semester’s Add/Drop period, which required multiple reviews and revisions to the student’s financial aid package. During one of the reviews, a staff member did not accurately increase the student’s Pell grant award when it was flagged by the system as being incorrect. As part of our corrective action, we have implemented additional reporting enhancements to review and confirm accurate awards. The reports are listed below: • The Office of Records and Registration will provide a comprehensive roster of student registration actions immediately following the Add/Drop period, and continuing weekly, until mid-semester, for review. • The Senior Business Analyst in the Financial Aid Office created an enhanced part-time user edit report of Pell students only who are not full-time at the end of the Add/Drop period for review. • The Analyst in the Financial Aid office developed a report to compare student enrollment intensity changes weekly, after the Add/Drop period is over, to identify and correct discrepancies in real time. The aforementioned corrective actions in the Financial Aid Office were fully operational for the Fall 2025 semester. Internal control reviews confirmed that no award errors occurred during the Fall 2025 term, validating the effectiveness of the new reporting and review structure. The College implemented the corrective action on 08/26/2025. Anticipated Completion Date: Completed in August 2025
While reimbursement requests submitted by the College were for expenditures incurred prior to the date of the reimbursement requests, certain reimbursement requests were not submitted within the specific time frames and with the requisite documentation required per the grant agreements. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for reimbursement requests per the grant agreements. Effect: While reimbursement requests submitted by the College were for expenditures incurred prior to the date of the reimbursement requests, certain reimbursement requests were not submitted within the specific time frames and with the requisite documentation required per the grant agreements. Questioned Costs: None. Context: Final reimbursement request for the “I Can Connect (ICC)” grant was not submitted within 12 days of the grant end date as indicated in the initial grant agreement. Final reimbursement request for the “I Can Connect (ICC)” grant was due by July 19, 2025 but it was not submitted until November 17, 2025. The reimbursement requests were missing certain required documentation elements outlined in the underlying grant agreements. Repeat Finding: No. Recommendation: It is recommended that management conduct a more thorough review of the grant agreements to ensure that all timing and supporting documentation requirements are met as they relate to reimbursement requests submitted to granting agencies. Views of Responsible Individuals: In response, the College strengthened control processes as it relates to reimbursement processing, including enhanced month-end procedures, hiring a staff member for additional oversight, strengthening communication, and establishing a grant-specific reimbursement tracker. In addition, a mandatory annual training will be implemented beginning in fiscal year 2026. Refer to the Corrective Action Plan for Current Year Findings.
Show full finding ▾Hide full finding ▴Finding 2025-003: Cash Management Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Criteria: In accordance with 2 CFR 200.305 (b)(3) and per the terms of the underlying grant agreements, the College is funded under the reimbursement method and therefore, cash drawdowns/reimbursement requests made during the period from the federal agency or pass-through entity should be for expenditures incurred prior to the date of the reimbursement request. Condition: While reimbursement requests submitted by the College were for expenditures incurred prior to the date of the reimbursement requests, certain reimbursement requests were not submitted within the specific time frames and with the requisite documentation required per the grant agreements. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for reimbursement requests per the grant agreements. Effect: While reimbursement requests submitted by the College were for expenditures incurred prior to the date of the reimbursement requests, certain reimbursement requests were not submitted within the specific time frames and with the requisite documentation required per the grant agreements. Questioned Costs: None. Context: Final reimbursement request for the “I Can Connect (ICC)” grant was not submitted within 12 days of the grant end date as indicated in the initial grant agreement. Final reimbursement request for the “I Can Connect (ICC)” grant was due by July 19, 2025 but it was not submitted until November 17, 2025. The reimbursement requests were missing certain required documentation elements outlined in the underlying grant agreements. Repeat Finding: No. Recommendation: It is recommended that management conduct a more thorough review of the grant agreements to ensure that all timing and supporting documentation requirements are met as they relate to reimbursement requests submitted to granting agencies. Views of Responsible Individuals: In response, the College strengthened control processes as it relates to reimbursement processing, including enhanced month-end procedures, hiring a staff member for additional oversight, strengthening communication, and establishing a grant-specific reimbursement tracker. In addition, a mandatory annual training will be implemented beginning in fiscal year 2026. Refer to the Corrective Action Plan for Current Year Findings.
Finding 2025-003: Cash Management Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Responsible Person: Karen Miller, Controller, 609-771-2203, Jeanette Vega, Director of Grant Financial Administration, 609-771-2847 Amy Cuhel-Shuckers, Director, Grants and Sponsored Research, 609-771-3120 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College had certain reimbursement requests under ALN 84.126A that were not submitted within the required timeframes and were missing certain documentation elements specified within the underlying grant agreements. While all reimbursement requests were made for allowable expenditures incurred prior to the date of request, the timing and documentation issues resulted from staff turnover and gaps in detailed review procedures within both Finance & Business Services and the Office of Grants and Sponsored Research (OGSR). The College recognizes the importance of ensuring that reimbursement requests are fully compliant with the timing and supporting documentation requirements outlined in 2 CFR 200.305 and the corresponding award documents. During FY25 and FY26, the College strengthened internal controls over reimbursement processing by implementing enhanced month-end monitoring procedures, hiring a Research Business Assistant responsible for additional oversight, improving documentation standards, strengthening cross-functional communication and coordination, and establishing a grant-specific reimbursement deadline tracker. These improvements were incorporated into updated training for principal investigators and grant support staff, with mandatory annual training implemented beginning FY26.The College implemented portions of the corrective actions during the fiscal year, with remaining items implemented at the start of FY26. These actions collectively support full and ongoing compliance with reimbursement requirements for federal and pass-through grant programs. Anticipated Completion Date: June 30, 2026
In accordance with the grant agreements, the College was required to provide certain quarterly and annual performance reports which were not submitted timely. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for periodic performance reporting per the grant agreements. Effect: Certain performance reports were not submitted timely in accordance with the requirements of the respective grant agreements. Questioned Costs: None. Context: For the “Transition TA & Administration” and “Summer Transition Programs” grants, the College was unable to produce evidence that performance reporting occurred timely and with the requisite approvals. Repeat Finding: No. Recommendation: It is recommended that management perform a more thorough review of specific reporting requirements related to the ALN 84.126A grant agreements to ensure that the College’s requirements as they relate to performance reporting requirements are met. Views of Responsible Individuals: In response, the College is looking to implement a centralized reporting and tracking system with reminders for deadlines as well as incorporating reviews over performance reporting into month-end procedures. Oversight over reporting has been added as part of the monthly Research Administration meetings, and the College is looking to expand support staff to assist with performance monitoring. Lastly, the College is planning to expand annual training requirements for all principal investigators and support staff. Refer to the Corrective Action Plan for Current Year Findings.
Show full finding ▾Hide full finding ▴Finding 2025-004: Reporting Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Criteria: Award recipients, as dictated by the grant agreements, may be required to provide performance reporting to the awarding agency in order to maintain funding. For performance reporting, non-federal entities may be required to submit performance reports at least annually but not more frequently than quarterly using a form or format authorized by the awarding agency (2 CFR 200.329). Condition: In accordance with the grant agreements, the College was required to provide certain quarterly and annual performance reports which were not submitted timely. Cause: Staff turnover within the Finance and Office of Grants and Sponsored Research (OGSR) prevented adequate levels of detailed review and understanding of the specific due dates and information requirements for periodic performance reporting per the grant agreements. Effect: Certain performance reports were not submitted timely in accordance with the requirements of the respective grant agreements. Questioned Costs: None. Context: For the “Transition TA & Administration” and “Summer Transition Programs” grants, the College was unable to produce evidence that performance reporting occurred timely and with the requisite approvals. Repeat Finding: No. Recommendation: It is recommended that management perform a more thorough review of specific reporting requirements related to the ALN 84.126A grant agreements to ensure that the College’s requirements as they relate to performance reporting requirements are met. Views of Responsible Individuals: In response, the College is looking to implement a centralized reporting and tracking system with reminders for deadlines as well as incorporating reviews over performance reporting into month-end procedures. Oversight over reporting has been added as part of the monthly Research Administration meetings, and the College is looking to expand support staff to assist with performance monitoring. Lastly, the College is planning to expand annual training requirements for all principal investigators and support staff. Refer to the Corrective Action Plan for Current Year Findings.
Finding 2025-004: Reporting Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Responsible Persons: Karen Miller, Controller, 609-771-2203, Jeanette Vega, Director of Grant Financial Administration, 609-771-2847 Amy Cuhel-Shuckers, Director, Grants and Sponsored Research, 609-771-3120 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College was unable to provide evidence that certain quarterly and annual performance reports required under the ALN 84.126A grant agreements were submitted timely and with the required approvals. These delays resulted from staffing vacancies, turnover, and insufficient tracking mechanisms for reporting deadlines across the supporting units. The College acknowledges the importance of ensuring accurate and timely performance reporting as required under 2 CFR 200.329 and the underlying award documents. To strengthen compliance, the College will look to implement a centralized reporting and tracking system with automated deadline reminders, incorporate performance reporting reviews into enhanced month-end monitoring procedures, strengthen cross-functional communication and coordination, and expand annual training requirements for all principal investigators and administrative support staff. Additionally, the College added performance-reporting oversight to its monthly Research Administration meetings. The College is also expanding support staff to assist with fiscal and performance monitoring. The College implemented portions of the corrective action beginning in FY25, with remaining actions implemented through December 31, 2026. These improvements are designed to ensure full compliance with sponsor-required reporting timelines going forward. Anticipated Completion Date: December 31, 2026
FAC accepted this audit on February 28, 2025 — management decision was due August 28, 2025.
Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Show full finding ▾Hide full finding ▴Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025
FAC accepted this audit on March 15, 2024 — management decision was due September 15, 2024.
There were inadequate review controls in place to prevent the input of incorrect figures into the FISAP report. Context: For the fiscal year ending June 30, 2023, the supporting documentation for the FISAP did not tie to the report that was submitted through COD for the following lines in Part II, Section F: 1) Line 29 Column C per the FISAP noted 0 students compared to 8 students in the underlying support. 2) Line 29 Column E, per the FISAP noted 0 compared to 16 students in the underlying support. 3) Line 34, Column E, per the FISAP, noted 12 students compared to 11 in the underlying support. Cause: The College's Executive Director of Financial Aid was unaware of any errors when submitting the FISAP report to the DOE via COD. Therefore, the review process was not precise enough to detect any errors before submitting to COD. Effect: The FISAP initially submitted through COD did not accurately reflect the College’s underlying records. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that management conduct a more thorough review of the FISAP report before submitting to the DOE so that any errors are rectified. Views of Responsible Officials and Planned Corrective Action: There were three data entry errors entered when submitting the FISAP for fiscal year 2023. The two sections reported zero (0) students were erroneously skipped, thus no data was entered, even though the support document had students listed there. One section where 12 students were reported but the support document had 11 was due to the excel support spreadsheet formula error that counted an additional column by mistake causing a data entry error. After the FISAP submission, the mistakes were discovered. The FISAP was reopened and the data was corrected. In completing the annual FISAP, the College will conduct a more thorough multi-level review of entries and support documents before submitting the report to the DOE. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023 and was able to resubmit the FISAP. Individual Responsible for Corrective Action: Wilbert Casaine, Executive Director of Student Financial Aid Anticipated Completion Date for Corrective Action: Completed
Show full finding ▾Hide full finding ▴Finding 2023-001: Reporting – Special Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2022 – June 30, 2023 Criteria: Schools are required to report to the Department of Education (DOE), via the COD (Common Origination and Disbursement) system, the Fiscal Operations Report and Application to Participate (FISAP). Per the 2023 Compliance Supplement, this electronic report is submitted annually to receive funds for the campus-based programs. The institution uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. By October 1, 2022, the institution should submit its FISAP that includes the Fiscal Operations Report for the award year 2021–2022 and the Application to Participate for the 2022–2023 award year. Condition: There were inadequate review controls in place to prevent the input of incorrect figures into the FISAP report. Context: For the fiscal year ending June 30, 2023, the supporting documentation for the FISAP did not tie to the report that was submitted through COD for the following lines in Part II, Section F: 1) Line 29 Column C per the FISAP noted 0 students compared to 8 students in the underlying support. 2) Line 29 Column E, per the FISAP noted 0 compared to 16 students in the underlying support. 3) Line 34, Column E, per the FISAP, noted 12 students compared to 11 in the underlying support. Cause: The College's Executive Director of Financial Aid was unaware of any errors when submitting the FISAP report to the DOE via COD. Therefore, the review process was not precise enough to detect any errors before submitting to COD. Effect: The FISAP initially submitted through COD did not accurately reflect the College’s underlying records. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that management conduct a more thorough review of the FISAP report before submitting to the DOE so that any errors are rectified. Views of Responsible Officials and Planned Corrective Action: There were three data entry errors entered when submitting the FISAP for fiscal year 2023. The two sections reported zero (0) students were erroneously skipped, thus no data was entered, even though the support document had students listed there. One section where 12 students were reported but the support document had 11 was due to the excel support spreadsheet formula error that counted an additional column by mistake causing a data entry error. After the FISAP submission, the mistakes were discovered. The FISAP was reopened and the data was corrected. In completing the annual FISAP, the College will conduct a more thorough multi-level review of entries and support documents before submitting the report to the DOE. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023 and was able to resubmit the FISAP. Individual Responsible for Corrective Action: Wilbert Casaine, Executive Director of Student Financial Aid Anticipated Completion Date for Corrective Action: Completed
Corrective Action Plan for Current Year Findings June 30, 2023 Finding 2023-001: Reporting – Special Reporting Student Financial Assistance Cluster U.S Department of Education Award Period: July 1, 2022 – June 30, 2023 Responsible Person: Wilbert Casaine, Executive Director of Student Financial Aid, 609-771-2211 Corrective Action Plan: For the fiscal year ending June 30, 2023, the supporting documentation for the FISAP did not tie to the report that was submitted through COD. The two sections reported zero (0) students were erroneously skipped, thus no data was entered, even though the support document had students listed there, for the following lines in Part II, Section F: Line 29 Column C per the FISAP noted 0 students, and 8 students in the underlying support. Line 29 Column E, per the FISAP noted 0, and 16 students in the underlying support. One section where 12 students were reported but the support document had 11 was due to the excel support spreadsheet formula error that counted an additional column causing data entry error for the following line: Line 34, Column E, per the FISAP, noted 12 students, and 11 in the underlying support. After the original FISAP submission, the data errors were discovered. The FISAP was reopened and the data was corrected. In completing the annual FISAP, the College will conduct a more thorough multi-level review of entries and support documents before submitting the report to the DOE. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023 and was able to resubmit the FISAP. The College implemented the corrective action on October 18, 2023 retroactive to July 1, 2023. Anticipated Completion Date: Completed
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
FAC accepted this audit on May 1, 2022 — management decision was due November 1, 2022.
FAC accepted this audit on March 25, 2021 — management decision was due September 25, 2021.
FAC accepted this audit on February 19, 2020 — management decision was due August 19, 2020.
FAC accepted this audit on March 29, 2019 — management decision was due September 29, 2019.
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2017-003
FAC accepted this audit on March 14, 2018 — management decision was due September 14, 2018.
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2016-001
FAC accepted this audit on March 23, 2017 — management decision was due September 23, 2017.
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