EIN: 231352642
UEI: PHA8ECZ7E2E3
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 29, 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 November 29, 2026 (94 days from today).
What is a management decision? →In two separate instances, the College refunded credit balances 112 days and 22 days after the first day of class without authorization to hold the balances. Cause: The College failed to process the refunds in a timely manner. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Identification of a Repeat Finding: 2024-002 Recommendation: We recommend that the College develop procedures and related controls to ensure a timely processing of the refunds.
Show full finding ▾Hide full finding ▴Finding 2025-004 Federal Assistance Listing Number: 84.268 Subprogram Number(s): 84.268 Federal Agency: U.S. Department of Education Program Name: Federal Direct Student Loans Type(s) of Compliance Requirements: Special Tests and Provisions Type of Finding: Internal Control over Compliance – Significant Deficiency; Noncompliance Criteria: Under the disbursement to or on behalf of students requirements, credit balances are to be paid to the student or parent borrower (1) within 14 days after (a) the first day of class of a payment period if the credit balance occurred on or before that day, or (b) the balance occurred if that was after the first day of class; or (2) if the institution obtained an authorization to hold credit balances and was not on the reimbursement or heightened cash monitoring payment methods, by the end of the loan period or last payment period in the award year for which the funds were awarded. Condition: In two separate instances, the College refunded credit balances 112 days and 22 days after the first day of class without authorization to hold the balances. Cause: The College failed to process the refunds in a timely manner. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Identification of a Repeat Finding: 2024-002 Recommendation: We recommend that the College develop procedures and related controls to ensure a timely processing of the refunds.
Finding 2025-004 Corrective Action Plan The Finance team will collaborate with the Director of Financial Aid and the Registrar to strengthen the format of notifications so that credit balances are paid to the students or parent borrowers within the required timeframe as outlined in the Federal Direct Student Loans Program. The corrective action plan is anticipated to be completed on or before August 31, 2026. Names of Contact People Responsible for Corrective Action Jeanne Cavalieri-Grover –Director of Fiancial Aid Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Karen West – Coordinator of Student Billing Jade Jackman – Registrar
2024-002
The College returned Title IV funds 79 days after the College became aware of the student's withdrawal. Cause: The College failed to process the return in a timely manner due to miscommunication between departments within the College. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College implement stronger internal controls and communication procedures to ensure timely return of Title IV funds within the required 45-day period. This includes establishing clear withdrawal notification protocols and monitoring processes.
Show full finding ▾Hide full finding ▴Finding 2025-005 Federal Assistance Listing Number: 84.268 Subprogram Number(s): 84.268 Federal Agency: U.S. Department of Education Program Name: Federal Direct Student Loans Type(s) of Compliance Requirements: Special Tests and Provisions Type of Finding: Internal Control over Compliance – Significant Deficiency; Noncompliance Criteria: Under the Return of Title IV Funds compliance requirement, institutions must return unearned Title IV funds to the U.S Department of Education within 45 days of the date the institution determines the student withdrew (or within 30 days for students who never began attendance). Condition: The College returned Title IV funds 79 days after the College became aware of the student's withdrawal. Cause: The College failed to process the return in a timely manner due to miscommunication between departments within the College. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College implement stronger internal controls and communication procedures to ensure timely return of Title IV funds within the required 45-day period. This includes establishing clear withdrawal notification protocols and monitoring processes.
Finding 2025-005 Corrective Action Plan The Finance team will collaborate with the Director of Financial Aid and the Registrar to strengthen the format of notifications to return Title IV funds within the required timeframe as outlined in the Federal Direct Student Loans Program. Anticipated Completion Date The corrective action plan is anticipated to be completed on or before August 31, 2026. Names of Contact People Responsible for Corrective Action Jeanne Cavalieri-Grover –Director of Fiancial Aid Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Karen West – Coordinator of Student Billing Jade Jackman – Registrar
FAC accepted this audit on April 16, 2025 — management decision was due October 16, 2025.
The College refunded a credit balance 22 days after the first day of class without authorization to hold the balance. Cause: The College failed to process the refund in a timely manner due to turnover in staff. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College develop procedures and related controls to ensure a timely processing of the refunds.
Show full finding ▾Hide full finding ▴Finding 2024-002 Federal Assistance Listing Number: 84.268 Subprogram Number(s): 84.268 Federal Agency: U.S. Department of Education Program Name: Federal Direct Student Loans Type(s) of Compliance Requirements: Special Tests and Provisions Type of Finding: Internal Control over Compliance – Significant Deficiency; Noncompliance Criteria: Under the disbursement to or on behalf of students requirements, credit balances are to be paid to the student or parent borrower (1) within 14 days after a) the first day of class of a payment period if the credit balance occurred on or before that day, or b) the balance occurred if that was after the first day of class or 2) if the institution obtained an authorization to hold credit balances and was not on the reimbursement or heightened cash monitoring payment methods, by the end of the loan period or last payment period in the award year for which the funds were awarded. Condition: The College refunded a credit balance 22 days after the first day of class without authorization to hold the balance. Cause: The College failed to process the refund in a timely manner due to turnover in staff. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College develop procedures and related controls to ensure a timely processing of the refunds.
Finding 2024-002 Corrective Action Plan The College reassigned the duties within its business office to ensure remittances to students or parent borrowers of credit balances are executed in accordance with the timeline mandated by the U.S. Department of Education. Gratz College notes that this was the only instance of noncompliance and resulted from turnover in Gratz College’s business office staff. Anticipated Completion Date The corrective action plan was completed June 1, 2024 Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Ross Holgado – Manager of Financial Reporting Karen West – Senior Accounting Associate and Coordinator of Student Billing
FAC accepted this audit on May 30, 2024 — management decision was due November 30, 2024.
The College posted quarterly reports to its website. However, the College was unable to provide documentation to support the timely posting of these reports. Cause: The College failed to develop and implement procedures to perform the reporting requirements. Effect: The College is noncompliant with the ESF program requirements. Context: 1 out of 2 quarterly reports selected for testing Identification of a Repeat Finding: 2022-002. Recommendation: We recommend that the College develop procedures and related controls over the reporting requirements of the ESF program.
Show full finding ▾Hide full finding ▴Finding 2023-001 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E, 84.425F, and 84.425N Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Reporting Type of Finding: Noncompliance Criteria: The College must publicly post quarterly forms on its website for the specific subprograms of the federal award. Condition: The College posted quarterly reports to its website. However, the College was unable to provide documentation to support the timely posting of these reports. Cause: The College failed to develop and implement procedures to perform the reporting requirements. Effect: The College is noncompliant with the ESF program requirements. Context: 1 out of 2 quarterly reports selected for testing Identification of a Repeat Finding: 2022-002. Recommendation: We recommend that the College develop procedures and related controls over the reporting requirements of the ESF program.
Finding 2023-001 Corrective Action Plan The College was posting quarterly forms based on its financial records to its website. However, the current platform that the College utilizes does not provide an activity log to show that these reports were posted in a timely manner. The College’s staff and management developed a checklist in response to Finding 2022-002 from the prior year to ensure that reporting, filing, and disbursement requirements for all grants will be met. The College’s management notes that the reports were filed with the U.S. Department of Education on time and were subsequently accepted. The College’s management further notes that these Federal programs have expired and does not anticipate further funding related to the Education Stabilization Fund. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2024. Name of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Ross Holgado – Manager of Financial Reporting
2022-002
The College withdrew the funds and did not disburse the funds until 537 days later (Institutional Aid Portion (CARES I & CARES II)), 609 days later (FIPSE – Student Aid), and 508 days later (Institutional Aid Portion (CARES III)). Cause: The College withdrew all funds remaining under each award as of December 21, 2021 with the understanding that the funds were expiring as of December 31, 2021. Effect: The College is noncompliant with the requirements under Cash Management. Context: 10 sample selections ($19,034) out of a sample of 10 items from a population of 34 items ($47,147) were tested. Identification of a Repeat Finding: 2022-005 Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Show full finding ▾Hide full finding ▴Finding 2023-002 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E, 84.425N, and 84.425F Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Cash Management Type of Finding: Internal Control over Compliance – Significant Deficiency; Noncompliance Criteria: Entities must minimize the time elapsing between the transfer of funds from the federal awarding agency and the disbursement of funds by the entity. Disbursements of student awards under the Student Aid Portion of HEERF should be disbursed within 15 calendar days of the drawdown form Department of Education's G5 grants system. Disbursements of funds from the Fund for the Improvement of Postsecondary Education (FIPSE) Formula Grant should be disbursed within 3 calendar days of the drawdown from G5. Condition: The College withdrew the funds and did not disburse the funds until 537 days later (Institutional Aid Portion (CARES I & CARES II)), 609 days later (FIPSE – Student Aid), and 508 days later (Institutional Aid Portion (CARES III)). Cause: The College withdrew all funds remaining under each award as of December 21, 2021 with the understanding that the funds were expiring as of December 31, 2021. Effect: The College is noncompliant with the requirements under Cash Management. Context: 10 sample selections ($19,034) out of a sample of 10 items from a population of 34 items ($47,147) were tested. Identification of a Repeat Finding: 2022-005 Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Finding 2023-002 Corrective Action Plan The College acknowledges that funds withdrawn for these subprograms were not disbursed in a timely manner. The College notes that although the funds were disbursed after the period required by the program (within 3 days of withdrawal for non-student aid expenses), the expenses paid were allowable under the guidance of the program. The College’s staff and management developed a checklist in response to Finding 2022-005 from the prior year to ensure that reporting, filing, and disbursement requirements for all grants will be met. The College’s management notes that these Federal programs have expired and does not anticipate further funding related to the Education Stabilization Fund. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2024. Name of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Ross Holgado – Manager of Financial Reporting
2022-005
The College withdrew all funds remaining in the G5 grants system, and had a balance of unspent funds at August 31, 2023. Cause: The College withdrew all funds remaining under each award as of December 21, 2021 with the understanding that the funds were expiring as of December 31, 2021. Effect: The College is noncompliant with the requirements under Cash Management. Identification of a Repeat Finding: 2022-006 Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Show full finding ▾Hide full finding ▴Finding 2023-003 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425F Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Cash Management Type of Finding: Noncompliance Criteria: Entities must minimize the time elapsing between the transfer of funds from the federal awarding agency and the disbursement of funds by the entity. Condition: The College withdrew all funds remaining in the G5 grants system, and had a balance of unspent funds at August 31, 2023. Cause: The College withdrew all funds remaining under each award as of December 21, 2021 with the understanding that the funds were expiring as of December 31, 2021. Effect: The College is noncompliant with the requirements under Cash Management. Identification of a Repeat Finding: 2022-006 Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Finding 2023-003 Corrective Action Plan The College acknowledges that there are unspent funds in this subprogram as of August 31, 2023. The College will return these unspent funds to the U.S. Department of Education before the close of the program’s fiscal quarter. The College’s management notes that these Federal programs have expired and does not anticipate further funding related to the Education Stabilization Fund. Anticipated Completion Date The College anticipates completion of this corrective action on or before July 10, 2024. Name of Contact Person Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities
2022-006
FAC accepted this audit on May 30, 2023 — management decision was due November 30, 2023.
The College was unable to provide documentation indicating the existence and implementation of internal controls over the Reporting compliance criteria and requirements for the Education Stabilization Fund (ESF) program. Cause: The College has written documentation to include the reporting requirements and related deadlines for the ESF program through December 31, 2021. However, internal controls over the preparation, reconciliation, and filing of the reports have not been designed and implemented. Effect: The internal control over the Reporting compliance requirement for the ESF program is likely to be ineffective in preventing or detecting noncompliance. Identification of a Repeat Finding: Finding 2021-002. Recommendation: We recommend that the College document the existence and implementation of internal controls over the Reporting compliance criteria for the ESF program.
Show full finding ▾Hide full finding ▴Finding 2022-001 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E, 84.425F, and 84.425N Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Reporting Type of Finding: Internal Control over Compliance - Material Weakness Criteria: The College is required to establish and maintain effective internal control over the federal award that provides reasonable assurance that the College is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The College was unable to provide documentation indicating the existence and implementation of internal controls over the Reporting compliance criteria and requirements for the Education Stabilization Fund (ESF) program. Cause: The College has written documentation to include the reporting requirements and related deadlines for the ESF program through December 31, 2021. However, internal controls over the preparation, reconciliation, and filing of the reports have not been designed and implemented. Effect: The internal control over the Reporting compliance requirement for the ESF program is likely to be ineffective in preventing or detecting noncompliance. Identification of a Repeat Finding: Finding 2021-002. Recommendation: We recommend that the College document the existence and implementation of internal controls over the Reporting compliance criteria for the ESF program.
Finding 2022-001 Corrective Action Plan The College has documentation indicating the existence and implementation of internal controls over Reporting compliance criteria for the ESF program. This documentation will be updated to include reporting requirements, specific report preparation and reconciliation procedures/controls and assessment of compliance with requirements of the respective grant. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
2021-002
The College posted quarterly reports to its website. However, the College was unable to provide data logs to support the timely posting of these reports. In addition, expenditures reported on the quarterly reports and in the annual reporting form for the period ended December 31, 2021 did not agree with the College's internal records. Cause: The College failed to develop procedures to perform the reporting requirements. Effect: The College is noncompliant with the ESF program requirements. Context: 2 out of 4 quarterly reports selected for testing; 1 annual report selected for testing Identification of a Repeat Finding: 2021-003. Recommendation: We recommend that the College develop procedures and related controls over the reporting requirements of the ESF program.
Show full finding ▾Hide full finding ▴Finding 2022-002 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E, 84.425F, and 84.425N Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Reporting Type of Finding: Noncompliance Criteria: The College must publicly post quarterly forms on its website for the specific subprograms of the federal award and submit an annual form to the ED reporting expenditures for the period ended December 31, 2021. Condition: The College posted quarterly reports to its website. However, the College was unable to provide data logs to support the timely posting of these reports. In addition, expenditures reported on the quarterly reports and in the annual reporting form for the period ended December 31, 2021 did not agree with the College's internal records. Cause: The College failed to develop procedures to perform the reporting requirements. Effect: The College is noncompliant with the ESF program requirements. Context: 2 out of 4 quarterly reports selected for testing; 1 annual report selected for testing Identification of a Repeat Finding: 2021-003. Recommendation: We recommend that the College develop procedures and related controls over the reporting requirements of the ESF program.
Finding 2022-002 Corrective Action Plan The College was posting quarterly forms based on its financial records to its website. However, the current platform that the College utilizes does not provide an activity log to show that these reports were posted in a timely manner. Going forward, the College will generate screenshots that will have a timestamp to show the timely posting of these reports. To ensure that quarterly reports submitted to the Department of Education and subsequently posted to the College?s website are accurate, the Manager of Business Operations and Facilities will work with the Manager of Financial Reporting to reconcile each report to internal records prior to submission. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Name of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
2021-003
The College expended Student Aid funds on the purchase of audio-visual equipment. Cause: The College misapplied funds drawn under the Student Aid Portion. Effect: The College is noncompliant with the ESF program. Context: 1 sample selection ($15,044) out of total sample of 1 item tested from a population of 3 items ($17,920). Recommendation: We recommend that the College develop a process to reconcile amounts drawn under the ESF to ensure the proper allocation and use of funds.
Show full finding ▾Hide full finding ▴Finding 2022-003 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Activities Allowed/Unallowed Type of Finding: Noncompliance Criteria: The Student Aid Portion of the Higher Education Emergency Relief Fund (HEERF) is to provide awards to students. Condition: The College expended Student Aid funds on the purchase of audio-visual equipment. Cause: The College misapplied funds drawn under the Student Aid Portion. Effect: The College is noncompliant with the ESF program. Context: 1 sample selection ($15,044) out of total sample of 1 item tested from a population of 3 items ($17,920). Recommendation: We recommend that the College develop a process to reconcile amounts drawn under the ESF to ensure the proper allocation and use of funds.
Finding 2022-003 Corrective Action Plan To ensure that funds drawn under the ESF properly allocated to the appropriate sub-program and are used in accordance with guidance provided by the granting agency, the College will develop a reconciliation process that includes a review of allowable use of funds under the granting agency?s grant award notification and a second review of the reconciliation of funds drawn and expended of the allocations made to the sub-programs against the College?s internal records. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Name of Contact Person Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
The College did not provide students with the option to receive the award directly. All awards were directed to the student's outstanding tuition balance. Cause: The College utilized the wrong form when administering grants to students. Effect: Students were prevented from receiving the awards directly. The College is noncompliant with the ESF program. Questioned Costs: $40,801 Context: 2 sample selections ($4,801) out of a total sample of 2 items tested from a population of 14 items ($40,801) resulted in errors. The full population of student awards was disbursed on a single date. The College acknowledged that all student awards disbursed on that single date utilized the form that directed the award to the student's tuition balance. Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Show full finding ▾Hide full finding ▴Finding 2022-004 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Activities Allowed/Unallowed Type of Finding: Material Noncompliance Criteria: Disbursements of student awards under the Student Aid Portion of HEERF are to provide the student with the option to receive the award directly or to apply the award to the student's outstanding tuition balance. Condition: The College did not provide students with the option to receive the award directly. All awards were directed to the student's outstanding tuition balance. Cause: The College utilized the wrong form when administering grants to students. Effect: Students were prevented from receiving the awards directly. The College is noncompliant with the ESF program. Questioned Costs: $40,801 Context: 2 sample selections ($4,801) out of a total sample of 2 items tested from a population of 14 items ($40,801) resulted in errors. The full population of student awards was disbursed on a single date. The College acknowledged that all student awards disbursed on that single date utilized the form that directed the award to the student's tuition balance. Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Finding 2022-004 Corrective Action Plan The College acknowledges that it erroneously applied the funds awarded to students to the incorrect subprogram. To ensure that federal funds are administered in accordance with program compliance requirements, the College will review and document, in summary form, all requirements made by the granting agency, including but not limited to proper use of funds, timeline for disbursement of federal funds, and reporting requirements. This documentation will be used by the responsible persons the ensure that the administration of the program and its related expenditures follow the guidelines of the granting agency Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
The College withdrew the funds and did not disburse the funds until 119 days later (Student Aid Portion), 35 days later (FIPSE - Institutional), and 15 days later (FIPSE ? Student Aid). Cause: The College withdrew funds under the Student Aid Portion (misapplied funds ? see Finding 2022-003) and under FIPSE to pay for the purchase of audio-visual equipment. Delivery of equipment and presentation of invoice were delayed, and therefore, the funds should have been returned to the G5 grants system. The College withdrew funds under FIPSE for student awards and applied the disbursement guidelines under the Student Aid Portion of HEERF rather than the disbursement guidelines under FIPSE. Effect: The College is noncompliant with the requirements under Cash Management. Context: 4 sample selections ($8,400) out of a sample of 7 items from a population of 68 items ($159,999) were tested. The portion of the population of student awards that was disbursed 15 days after the draw from G5 was 46 items ($95,800). Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Show full finding ▾Hide full finding ▴Finding 2022-005 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E and 84.425N Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Cash Management Type of Finding: Internal Control over Compliance ? Significant Deficiency; Noncompliance Criteria: Entities must minimize the time elapsing between the transfer of funds from the federal awarding agency and the disbursement of funds by the entity. Disbursements of student awards under the Student Aid Portion of HEERF should be disbursed within 15 calendar days of the drawdown form Department of Education's G5 grants system. Disbursements of funds from the Fund for the Improvement of Postsecondary Education (FIPSE) Formula Grant should be disbursed within 3 calendar days of the drawdown from G5. Condition: The College withdrew the funds and did not disburse the funds until 119 days later (Student Aid Portion), 35 days later (FIPSE - Institutional), and 15 days later (FIPSE ? Student Aid). Cause: The College withdrew funds under the Student Aid Portion (misapplied funds ? see Finding 2022-003) and under FIPSE to pay for the purchase of audio-visual equipment. Delivery of equipment and presentation of invoice were delayed, and therefore, the funds should have been returned to the G5 grants system. The College withdrew funds under FIPSE for student awards and applied the disbursement guidelines under the Student Aid Portion of HEERF rather than the disbursement guidelines under FIPSE. Effect: The College is noncompliant with the requirements under Cash Management. Context: 4 sample selections ($8,400) out of a sample of 7 items from a population of 68 items ($159,999) were tested. The portion of the population of student awards that was disbursed 15 days after the draw from G5 was 46 items ($95,800). Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Finding 2022-005 Corrective Action Plan To ensure that disbursements of Federal awards are made within the allowed timeframe, the Manager of Business Operations and Facilities and the Manager of Financial Reporting will review the program requirements of each award and document these disbursement requirements on the College?s reconciliation of grant funds expended prior to drawing down funds. Dates will be added to the College?s reconciliation of grant funds to indicate the last day when funds must be disbursed. Any remaining funds after this date will be returned to the granting agency. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
The College withdrew all funds remaining in the G5 grants system and did not disburse the funds. Cause: The College withdrew all funds remaining under each award as of December 21, 2021 with the understanding that the funds were expiring as of December 31, 2021. Effect: The College is noncompliant with the requirements under Cash Management. Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Show full finding ▾Hide full finding ▴Finding 2022-006 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E, 84.425F, and 84.425N Federal Agency: U.S. Department of Education Program Name: Education Stabilization Fund Type(s) of Compliance Requirements: Cash Management Type of Finding: Noncompliance Criteria: Entities must minimize the time elapsing between the transfer of funds from the federal awarding agency and the disbursement of funds by the entity. Condition: The College withdrew all funds remaining in the G5 grants system and did not disburse the funds. Cause: The College withdrew all funds remaining under each award as of December 21, 2021 with the understanding that the funds were expiring as of December 31, 2021. Effect: The College is noncompliant with the requirements under Cash Management. Recommendation: We recommend that the College develop and implement procedures to ensure that federal funds are administered in accordance with program compliance requirements.
Finding 2022-006 Corrective Action Plan The College acknowledges withdrawing all remaining funds from the appropriate awarding agency before the expiration date of December 31, 2021. However, it should be noted that the disbursement of these funds drawn was in anticipation of settling an invoice for an allowable expense within three calendar days of the draw. However, because of unforeseen delays on the part of the vendor, the invoice was settled outside of this timeframe. It should be further noted that all funds drawn are kept in a non-interest bearing bank account separate from the College?s normal operating account (from which all vendor invoices are paid) until the funds are disbursed. Upon disbursement, the funds are then transferred to the College?s operating account. To ensure that disbursements of federal awards are made within the allowed timeframe, the College?s management will have received an invoice for an allowable expenditure before withdrawing federal funds to settle that invoice. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2023. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
FAC accepted this audit on March 23, 2022 — management decision was due September 23, 2022.
The College returned Title IV funds to the ED within 48 days after becoming aware that the student had withdrawn from the course. Cause: The College failed to process the return in a timely manner. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College implement procedures to ensure proper communication between the Financial Aid Office and Business Office resulting in a timely processing of Title IV returns.
Show full finding ▾Hide full finding ▴Finding 2021-001 Federal Assistance Listing Number: 84.268 Subprogram Number(s): N/A Program Name: Federal Direct Student Loans Type(s) of Compliance Requirements: Special tests and provisions Type of Finding: Noncompliance Criteria: Any unearned Title IV funds must be returned to the Department of Education (ED) no later than 45 days after the date that the institution determines that the student withdrew. Condition: The College returned Title IV funds to the ED within 48 days after becoming aware that the student had withdrawn from the course. Cause: The College failed to process the return in a timely manner. Effect: The College is noncompliant with the requirements of the Student Financial Aid program. Recommendation: We recommend that the College implement procedures to ensure proper communication between the Financial Aid Office and Business Office resulting in a timely processing of Title IV returns.
Finding 2021-001 Corrective Action Plan Gratz College returned loan funds three days late after a student dropped a class due to health related issues. When the student reduced his course load, the reduction represented a change in enrollment status, not a withdrawal. Therefore, no Return of Title IV Funds (R2T4) calculation was required. The student became ineligible for his federal student aid for the semester because he no longer met the basic eligibility requirement of being enrolled at least half-time in a degree-seeking program. Dropping credits jeopardizes a student?s financial aid eligibility, including their eligibility for Federal Direct Loans. If a student drops below half-time status (less than 6 credits as an undergraduate and 4.5 credits as a graduate student), the student will become ineligible for Federal Loans. Dropping classes does not constitute a formal withdrawal from the College. Dropping is a process of reducing a course load for a particular semester. Financial aid may be adjusted if the aid source requires full-time or half-time enrollment and the students credits drop below the minimum required. Gratz College acknowledges that it must return funds no later than 45 days after it determines the student changed their enrollment status which made them ineligible for financial aid funds. Gratz College uses the G5 system to return funds electronically. To ensure all funds are returned and processed in a timely manner, Gratz College will do the following: ? The Registrar will develop a report in the college?s administrative software system to monitor all financial aid recipients who have dropped a class/or classes during the semester. ? This report will be sent to the Bursar and the Director of Financial Aid on a weekly basis for review. ? All financial aid recipients who do not meet the enrollment eligibility requirements for the semester will have their Federal loans/grants returned through the G5 system within the required timeframe. ? The student will have their student account adjusted to reflect the return of funds. Dropping classes (outside of the drop/add period) does not relieve a student of their financial obligation to Gratz College for any unpaid charges (including financial aid adjustments/returns) incurred for the related semester. Anticipated Completion Date The College anticipates completion of this corrective action on or before February 28, 2022. Names of Contact People Responsible for Corrective Action Jeanne Cavalieri-Grover ? Manager of Financial Aid Karen West ? Senior Accounting Associate
The College was unable to provide documentation indicating the existence and implementation of internal controls over the Reporting compliance criteria for the Education Stabilization Fund (ESF) program. Cause: The College was unable to find clear guidance on the Reporting requirement and did not establish written documentation related to the existence and implementation of internal controls over applicable compliance criteria for the ESF program. Effect: The internal control over the Reporting compliance requirement for the ESF program is likely to be ineffective in preventing or detecting noncompliance. We have determined this to be a material weakness in internal control over compliance. Recommendation: We recommend that the College document the existence and implementation of internal controls over the Reporting compliance criteria for the ESF program.
Show full finding ▾Hide full finding ▴Finding 2021-002 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E and 84.425N Program Name: Education Stabilization Program Fund Type(s) of Compliance Requirements: Reporting Type of Finding: Material Weakness Criteria: The College is required to establish and maintain effective internal control over the federal awards that provides reasonable assurance that the College is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: The College was unable to provide documentation indicating the existence and implementation of internal controls over the Reporting compliance criteria for the Education Stabilization Fund (ESF) program. Cause: The College was unable to find clear guidance on the Reporting requirement and did not establish written documentation related to the existence and implementation of internal controls over applicable compliance criteria for the ESF program. Effect: The internal control over the Reporting compliance requirement for the ESF program is likely to be ineffective in preventing or detecting noncompliance. We have determined this to be a material weakness in internal control over compliance. Recommendation: We recommend that the College document the existence and implementation of internal controls over the Reporting compliance criteria for the ESF program.
Finding 2021-002 Corrective Action Plan The College has documentation indicating the existence and implementation of internal controls over Reporting compliance criteria for the ESF program. This documentation will be updated to include reporting requirements. It should be noted that the College received correspondence dated January 26, 2022 from the United States Department of Education (the Department) indicating that the Department completed a final review of grant P425N200886 and determined that the terms and conditions of the grant were met and in compliance with the 2 CFR ? 200.344. The Department officially closed this grant. Anticipated Completion Date The College anticipates completion of this corrective action on or before February 28, 2022. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
The College only posted one quarterly report on its website. In addition, in the annual reporting form for the period ended December 31, 2020, the College did not report any expenditures, which is not in agreement with the College's internal records. Cause: The College was not aware of the requirement to publicly post reports on its website each quarter or report all expenditures in the 2020 annual report. Effect: The College is noncompliant with the ESF program requirements. Recommendation: We recommend that the College complete missing quarterly forms based on its internal financial records and post them to its website. We also recommend that the College reach out to its ED representative to inquire about resubmission of the 2020 annual report reflecting actual expenditures incurred for the period ended December 31, 2020.
Show full finding ▾Hide full finding ▴Finding 2021-003 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425E and 84.425N Program Name: Education Stabilization Program Fund Type(s) of Compliance Requirements: Reporting Type of Finding: Noncompliance Criteria: The College must publicly post quarterly forms on its website for both the Student Aid Portion and the Institutional Portion of the federal award and submit an annual form to the ED reporting expenditures for the period ended December 31, 2020. Condition: The College only posted one quarterly report on its website. In addition, in the annual reporting form for the period ended December 31, 2020, the College did not report any expenditures, which is not in agreement with the College's internal records. Cause: The College was not aware of the requirement to publicly post reports on its website each quarter or report all expenditures in the 2020 annual report. Effect: The College is noncompliant with the ESF program requirements. Recommendation: We recommend that the College complete missing quarterly forms based on its internal financial records and post them to its website. We also recommend that the College reach out to its ED representative to inquire about resubmission of the 2020 annual report reflecting actual expenditures incurred for the period ended December 31, 2020.
Finding 2021-003 Corrective Action Plan The College will post quarterly forms based on its financial records to its website. The College deems resubmission of the report to the Department for the period ended December 31, 2020 as unnecessary since there have been no changes in the amount of reported expenditures between the date of the original submission and the date of this report. Anticipated Completion Date The College anticipates completion of this corrective action on or before February 28, 2022. Name of Contact Person Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities
The College expended funds on unallowable activity (event management services for a fundraising event). Cause: The College determined that this expenditure can be reimbursed under the provisions for lost revenue. Effect: The College is noncompliant with the ESF program requirements. Recommendation: We recommend that the College review and follow the applicable requirements of the ESF program to stay in compliance.
Show full finding ▾Hide full finding ▴Finding 2021-004 Federal Assistance Listing Number: 84.425 Subprogram Number(s): 84.425N Program Name: Education Stabilization Program Fund Type(s) of Compliance Requirements: Activities allowed or unallowed Type of Finding: Noncompliance Criteria: Institutions must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the ESF to prevent, prepare for, and respond to coronavirus. Condition: The College expended funds on unallowable activity (event management services for a fundraising event). Cause: The College determined that this expenditure can be reimbursed under the provisions for lost revenue. Effect: The College is noncompliant with the ESF program requirements. Recommendation: We recommend that the College review and follow the applicable requirements of the ESF program to stay in compliance.
Finding 2021-004 Corrective Action Plan It is the College?s position that the expenditure for event management services for this specific event totaled $15,000 to one vendor and was a necessary to salvage this event for which a significant amount of revenue was budgeted. The College understands that lost revenue from contributions cannot be funded from Federal funds, however, a significant portion of the budgeted revenue comes from sales of advertising and tickets which was lost because the event could not be held live and in-person due to the COVID-19 pandemic. It was necessary to engage the vendor to assist in the production of the event remotely due to the high-profile nature of the guest speaker and local attendance restrictions. It should be noted that the College received correspondence dated January 26, 2022 from the United States Department of Education (the Department) indicating that the Department completed a final review of grant P425N200886 and determined that the terms and conditions of the grant were met and in compliance with the 2 CFR ? 200.344. The Department officially closed this grant. It is from this grant that this expenditure was paid. The College will review and follow the applicable requirements of the ESF program in order to be in compliance. Anticipated Completion Date The College anticipates completion of this corrective action on or before February 28, 2022. Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. ? Manager of Business Operations and Facilities Ross Holgado ? Manager of Financial Reporting
FAC accepted this audit on February 24, 2021 — management decision was due August 24, 2021.
The College was unable to provide support for the monthly reconciliation of the SAS data file to the College's financial records. Cause: The College has not yet implemented reconciliation procedures. Effect: We were unable to determine if SAS data files were reconciled to the College's financial records each month. Recommendation: We recommend that the College implement procedures to perform the monthly reconciliation of the SAS data file to the College's financial records.
Show full finding ▾Hide full finding ▴2020-001 Reconciliation with the Department of Education Data File Criteria: The College is to reconcile the School Account Statement (SAS) data file, as provided by the Common Origination and Disbursement (COD) on a monthly basis, to the College's financial records. Condition: The College was unable to provide support for the monthly reconciliation of the SAS data file to the College's financial records. Cause: The College has not yet implemented reconciliation procedures. Effect: We were unable to determine if SAS data files were reconciled to the College's financial records each month. Recommendation: We recommend that the College implement procedures to perform the monthly reconciliation of the SAS data file to the College's financial records.
Finding: 2020-001 Reconciliation with the Department of Education Data File Corrective Action Plan To maintain proper segregation of duties, the Manager of Financial Reporting will reconcile, on a monthly basis, the SAS data file from the COD to the College?s financial records. The Financial Aid Office will provide the SAS data file and the Senior Accountant will provide the appropriate student billing reports to the Financial Reporting Manager. Anticipated Completion Date As part of its normal closing procedures, the Manager of Financial Reporting will perform this reconciliation beginning with the month ending January 31, 2021. Name of Contact Person Responsible for Corrective Action Ross Holgado ? Manager of Financial Reporting
2019-003
FAC accepted this audit on May 28, 2020 — management decision was due November 28, 2020.
The Department of Education bank account was not reconciled in a timely manner. The August 2019 reconciliation was completed in January 2020. Cause: Management fell behind in completing the reconciliation for the Department of Education bank account. Effect: Activity in the bank account may not agree with the College's financial records, and errors may not be detected in a timely manner. Recommendation: We recommend that management reconcile the Department of Education bank account on a monthly basis in a timely manner.
Show full finding ▾Hide full finding ▴2019-002 Reconciliation of the Department of Education bank account Criteria: Bank accounts are reconciled on a monthly basis in a timely manner. Condition: The Department of Education bank account was not reconciled in a timely manner. The August 2019 reconciliation was completed in January 2020. Cause: Management fell behind in completing the reconciliation for the Department of Education bank account. Effect: Activity in the bank account may not agree with the College's financial records, and errors may not be detected in a timely manner. Recommendation: We recommend that management reconcile the Department of Education bank account on a monthly basis in a timely manner.
Finding: 2019-002 Reconciliation of the Department of Education Bank Account Corrective Action Plan Gratz College finance department has a policy in place of reconciling all bank accounts on a monthly basis. A delay resulted in the preparation of this particular reconciliation due to a reconciling item which was resolved. To expedite the month-end close, reconciling items will be noted on future bank reconciliations (if needed) to ensure that these items are resolved in a more timely basis. Anticipated Completion Date Gratz College finance department made this procedural change effective immediately. Name of Contact Person Responsible for Corrective Action Karen West ? Senior Accounting Associate
The College was unable to provide support for the monthly reconciliation of the SAS data file to the College's financial records. Cause: The College was not aware of the reconciliation requirements for the Direct Loans. Effect: We were unable to determine if SAS data files were reconciled to the College's financial records each month. Recommendation: We recommend that the College implement procedures to perform the monthly reconciliation of the SAS data file to the College's financial records.
Show full finding ▾Hide full finding ▴2019-003 Reconciliation with the Department of Education Data File Criteria: The College is to reconcile the School Account Statement (SAS) data file, as provided by the Common Origination and Disbursement (COD) on a monthly basis, to the College's financial records. Condition: The College was unable to provide support for the monthly reconciliation of the SAS data file to the College's financial records. Cause: The College was not aware of the reconciliation requirements for the Direct Loans. Effect: We were unable to determine if SAS data files were reconciled to the College's financial records each month. Recommendation: We recommend that the College implement procedures to perform the monthly reconciliation of the SAS data file to the College's financial records.
Finding: 2019-003 Reconciliation with the Department of Education Data File Corrective Action Plan To be in compliance with reconciliation requirements for direct loans, Gratz College will put procedures into place to ensure that the reconciliation of the School Account Statement (SAS) data file as provided by the Common Origination and Disbursement (COD) to Gratz College?s financial records is performed and documented on a monthly basis. This will become a part of the monthly close process. Anticipated Completion Date August 31, 2020 Name of Contact Person Responsible for Corrective Action To be coordinated between Karen West (Senior Accounting Associate) and Jeanne Cavalieri-Grover (Financial Aid Office)
The College had an excess cash balance of $6,719 that was not returned within seven calendar days. Cause: The College failed to identify the excess cash balance as the College did not reconcile the cash activity per ED to the College's disbursement records on a timely basis. Effect: The excess cash balance of $6,719 was not returned to ED until January 2020. Recommendation: We recommend that the College implement procedures to reconcile the cash activity per ED to the College's disbursements records on a timely basis.
Show full finding ▾Hide full finding ▴2019-004: Cash Management under the advance payment method Criteria: Any Title IV funds drawn down under the advance payment method but not disbursed by the end of the third business day are considered to be excess cash, and generally are required to be promptly returned to the Department of Education (ED). The excess cash balance is to be eliminated within the next seven calendar days. Condition: The College had an excess cash balance of $6,719 that was not returned within seven calendar days. Cause: The College failed to identify the excess cash balance as the College did not reconcile the cash activity per ED to the College's disbursement records on a timely basis. Effect: The excess cash balance of $6,719 was not returned to ED until January 2020. Recommendation: We recommend that the College implement procedures to reconcile the cash activity per ED to the College's disbursements records on a timely basis.
Finding: 2019-004 Cash Management under the Advance Payment Method Corrective Action Plan All Title IV funds drawn down under the advance payment method will be disbursed by the end of the third business day. Once the Business Office receives the Loan Disbursement Report, all loan funding will be credited to the student's account within the three- day time period to remain compliant with the Department of Education regulations. The reconciliation process proposed in Finding 2019-003 will be performed to ensure that draw downs are accurate and done in a timely manner. Anticipated Completion Date August 31, 2020 Name of Contact Person Responsible for Corrective Action Karen West ? Senior Accounting Associate
The College does not have a documented quality assurance system. Cause: The College was not aware of the requirement to implement and document a quality assurance system under the Direct Loan program. Effect: The College is noncompliant with the requirements of the Direct Loan program. Recommendation: We recommend that the College implement and document a quality assurance system to comply with the requirements of the Direct Loan program.
Show full finding ▾Hide full finding ▴2019-005 Direct Loan Quality Assurance System Criteria: Under the Direct Loan program, the College is required to implement and document a quality assurance system. Condition: The College does not have a documented quality assurance system. Cause: The College was not aware of the requirement to implement and document a quality assurance system under the Direct Loan program. Effect: The College is noncompliant with the requirements of the Direct Loan program. Recommendation: We recommend that the College implement and document a quality assurance system to comply with the requirements of the Direct Loan program.
Finding: 2019-005 Direct Loan Quality Assurance System Corrective Action Plan The Federal Direct Loan program regulations require schools to implement and document a quality assurance process to ensure that they are complying with program requirements and meeting program objectives. In accordance with the Federal Direct Loan program, Gratz College has implemented and documented a quality assurance process to ensure we are complying with program requirements and meeting program objectives that ensures: 1. Reports loan origination records, disbursements records and adjustments to disbursements correctly to the Common Origination Disbursement (COD) system. 2. Disburses and returns loan funds in accordance with regulatory requirements. 3. Disburses the correct loan amount to the correct student. 4. Completes monthly reconciliation and year end closeout. PROCEDURES: 1. The Financial Aid Office will import files into the EDExpress financial aid software system and review any origination and disbursement edit reports and response reports. 2. These reports will be reviewed by the Financial Aid Office for any reported errors. 3. Any errors will be corrected and resubmitted to COD. 4. All student records will be verified by the Financial Aid Office and if a correction is needed, the correction will be made. 5. Corrections to the student?s record will be submitted to COD. 6. Corrections to the student?s record will be verified by the Financial Aid Office. 7. Any return of student loan funds will be submitted back to the Department of Education through the adjustments made to student?s loan record in EDExpress and if necessary through the G5 system. 8. The students? origination record will be decreased by the amount calculated per the Return to Title IV (R2T4) worksheet, if necessary. 9. An adjustment to the student?s record will be made for the amount calculated through the R2T4 process, if necessary. 10. Verification of adjustment of funds made to the student record for R2T4 will be verified by the Financial Aid Office. 11. Month-end Federal Direct Loan reconciliation will be completed by the Financial Aid Office. 12. Year-end Federal Direct Loan program closeout will be completed by the Financial Aid Office. The Financial Aid Office will receive the balance confirmation report from COD and verify that Gratz?s ending loan balance agrees with COD?s ending balance, which should be zero. Reconciliation procedures and related internal controls for this process will be added to the College?s Financial Aid Office Polices and Procedures Manual to ensure adequate documentation of these procedures and controls and consistent performance of the steps involved. Anticipated Completion Date 2019-2020 Academic Year Name of Contact Person Responsible for Corrective Action Financial Aid Office, Jeanne Cavalieri-Grover
FAC accepted this audit on May 30, 2018 — management decision was due November 30, 2018.
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2015-002
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