EIN: 231352632
UEI: ZPCVJYTH2VV1
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 September 30, 2026 (38 days from today).
What is a management decision? →During our audit, 1 out of 3 employees selected for testing received a bonus payment for achieving first year enrollment goals. The College then determined 2 employees received such bonuses and additional testing confirmed a total of 2 out of 27 employees who were involved in the College's admissions/recruiting, financial aid and registrar offices received bonuses based on their contributions towards enrollment performance. These bonuses were paid from internal College funds and not from Title IV funds. The sample was not a statistically valid sample but was determined using Chapter 21 - "Audit Sampling Considerations of Uniform Guidance Compliance Audits" of the Government Auditing Standards and Single Audit Guide. Cause: The College did not have a process for reviewing bonuses to employees to ensure they were offered in compliance with 34 CFR 668.14(b)(22). Effect: The College was not in compliance with 34 CFR 668.14(b)(22). Questioned Costs: $10,000 in bonus payments. Recommendation: We recognize that, as more fully described below, the College has since established and set in place a policy whereby incentive compensation is reviewed and approved to ensure compliance with 34 CFR 668.14(b)(22). We acknowledge this enhancement to the College’s internal control over compliance and encourage continued adherence to this policy moving forward. Views of Responsible Officials and Planned Corrective Actions: The College reviewed the finding and consulted with legal counsel and determined a formal college policy was needed. The Vice President for Finance and Assistant Vice President for Human Resources drafted a policy on incentive compensation that was reviewed and approved by senior leadership. The policy, along with a standard template for additional compensation, has been published to the human resources website for employees and managers as a resource for future awarding of compensation.
Show full finding ▾Hide full finding ▴Finding 2025-001 - Incentive Compensation Federal Programs: Student Financial Assistance Cluster Federal Award Numbers: 84.007, 84.033, 84.038, 84.063, 84.268 Federal Award Year: June 30, 2025 Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Criteria: Per 34 CFR 668.14(b)(22), institutions participating in Title IV federal student aid programs are prohibited from providing any commission, bonus, or other incentive payment to individuals or entities based directly or indirectly on their success in securing enrollments or financial aid. The fact that enrollment is a core responsibility does not exempt the institution from the ban. Condition: During our audit, 1 out of 3 employees selected for testing received a bonus payment for achieving first year enrollment goals. The College then determined 2 employees received such bonuses and additional testing confirmed a total of 2 out of 27 employees who were involved in the College's admissions/recruiting, financial aid and registrar offices received bonuses based on their contributions towards enrollment performance. These bonuses were paid from internal College funds and not from Title IV funds. The sample was not a statistically valid sample but was determined using Chapter 21 - "Audit Sampling Considerations of Uniform Guidance Compliance Audits" of the Government Auditing Standards and Single Audit Guide. Cause: The College did not have a process for reviewing bonuses to employees to ensure they were offered in compliance with 34 CFR 668.14(b)(22). Effect: The College was not in compliance with 34 CFR 668.14(b)(22). Questioned Costs: $10,000 in bonus payments. Recommendation: We recognize that, as more fully described below, the College has since established and set in place a policy whereby incentive compensation is reviewed and approved to ensure compliance with 34 CFR 668.14(b)(22). We acknowledge this enhancement to the College’s internal control over compliance and encourage continued adherence to this policy moving forward. Views of Responsible Officials and Planned Corrective Actions: The College reviewed the finding and consulted with legal counsel and determined a formal college policy was needed. The Vice President for Finance and Assistant Vice President for Human Resources drafted a policy on incentive compensation that was reviewed and approved by senior leadership. The policy, along with a standard template for additional compensation, has been published to the human resources website for employees and managers as a resource for future awarding of compensation.
Finding 2025-001 Condition During our audit, 1 out of 3 employees selected for testing received a bonus payment for achieving first year enrollment goals. The College then determined 2 employees received such bonuses and additional testing confirmed a total of 2 out of 27 employees who were involved in the College's admissions/recruiting, financial aid and registrar offices received bonuses based on their contributions towards enrollment performance. These bonuses were paid from internal College funds and not from Title IV funds. Corrective Action Plan Corrective Action Planned: The college implemented a policy on incentive pay citing the restrictions and banning incentive pay for specific job duties. The policy and a standard form for awarding additional compensation have been reviewed and approved by senior leadership and posted to the college’s human resources website. Name(s) of Contact Person(s) Responsible for Corrective Action: Amanda Stahl, Vice President for Finance and Ann Eckert, Assistant Vice President for Human Resources will be responsible for ensuring adherence to the policy and review of any awarding of additional compensation. Anticipated Completion Date: The policy and forms were approved and completed September 30, 2025.
FAC accepted this audit on November 26, 2018 — management decision was due May 26, 2019.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on November 19, 2017 — management decision was due May 19, 2018.
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GSA_MIGRATION
2016-001
FAC accepted this audit on November 15, 2016 — management decision was due May 15, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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