EIN: 231365966
UEI: FUPUKB23DQB6
Audited by: Baker Tilly US, LLP
Oversight agency: 84 [Department of Education]
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (34 days from today).
What is a management decision? →Finding 2025-001: Internal Control over Financial Reporting (Material Weakness) Criteria: Internal control is a process which captures and properly records transactions, safeguards assets and assures compliance with laws and regulations. One critical element of internal control includes periodic reconciliations of accounts to supporting documentation to ensure accurate periodic and yearend financial reporting. Condition/Context: During the audit of the College's financial statements for the fiscal year ended June 30, 2025, we identified deficiencies in internal control over financial reporting that, in the aggregate, constitute a material weakness. Specifically, we noted failure to reconcile cash accounts in a timely and accurate manner, and inaccurate accounting for investments, right-of-use assets, financing lease liability, long-term debt, and net assets (equity). Cause: Internal controls did not establish a procedure for accurately reconciled accounts on a routine basis. Effect: The above constitutes a weakness in internal control over financial reporting resulting in errors that needed to be corrected through journal entries. Recommendation: We recommend that the College establish a process to reconcile supporting records to the trial balance and ensure these reconciliations are reviewed by the appropriate personnel. Management's Response: Management acknowledges the finding and is committed to implementing a timely closing process. The College hired a new controller to assist with the timeliness of bank reconciliations and onboarded additional external resources to support the timeliness and accuracy of reporting of all financial statement line items.
Show full finding ▾Hide full finding ▴Finding 2025-001: Internal Control over Financial Reporting (Material Weakness) Criteria: Internal control is a process which captures and properly records transactions, safeguards assets and assures compliance with laws and regulations. One critical element of internal control includes periodic reconciliations of accounts to supporting documentation to ensure accurate periodic and yearend financial reporting. Condition/Context: During the audit of the College's financial statements for the fiscal year ended June 30, 2025, we identified deficiencies in internal control over financial reporting that, in the aggregate, constitute a material weakness. Specifically, we noted failure to reconcile cash accounts in a timely and accurate manner, and inaccurate accounting for investments, right-of-use assets, financing lease liability, long-term debt, and net assets (equity). Cause: Internal controls did not establish a procedure for accurately reconciled accounts on a routine basis. Effect: The above constitutes a weakness in internal control over financial reporting resulting in errors that needed to be corrected through journal entries. Recommendation: We recommend that the College establish a process to reconcile supporting records to the trial balance and ensure these reconciliations are reviewed by the appropriate personnel. Management's Response: Management acknowledges the finding and is committed to implementing a timely closing process. The College hired a new controller to assist with the timeliness of bank reconciliations and onboarded additional external resources to support the timeliness and accuracy of reporting of all financial statement line items.
Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and is committed to implementing a timely closing process. The College hired a new controller to assist with the timeliness of bank reconciliations and onboarded additional external resources.
For three withdrawn students, the College erroneously reported the effective date of the withdrawal. For six students, the college did not report their status to NSLDS within the 60 day threshold. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of students to the NSLDS due to turnover within the College at key positions within the student financial aid department including the registrar and bursars office. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related processes to accommodate both the internal enrollment polices and required reporting statuses and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
Show full finding ▾Hide full finding ▴Finding 2025-002: Enrollment Reporting - Material Weakness Repeat Finding: 2024-001 ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program Award Year: July 1, 2024 - June 30, 2025 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (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. Condition: For three withdrawn students, the College erroneously reported the effective date of the withdrawal. For six students, the college did not report their status to NSLDS within the 60 day threshold. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of students to the NSLDS due to turnover within the College at key positions within the student financial aid department including the registrar and bursars office. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related processes to accommodate both the internal enrollment polices and required reporting statuses and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
Views of Responsible Officials and Planned Corrective Actions: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related processes to accommodate both the internal enrollment polices and required reporting statuses and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
2024-001
For three students tested, the semester parameters utilized by the College were inaccurate. As a result, the use of an incorrect total number of days caused the amounts required to be returned under Title IV to be either understated or overstated, and similarly affected the calculation of a post-withdrawal disbursement for one student. Cause: The College had turnover in staffing within the financial aid department during the year. The College incorrectly input the number of days in the spring semester used for the return of title IV calculation causing the College to over refund students. Effect: The amounts refunded to the Department of Education may be incorrect. Questioned Costs: $61 Context: There were 67 students who withdrew during the fiscal year and were subject to the applicable testing requirements. From this population, 7 students were selected for testing. The sample was not statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: The College acknowledges and concurs with the finding. The College is now contracting with FA Solutions to assist with student financial aid reporting. FA Solutions is considered an expert 3rd party service provider and the College will ensure that they have the appropriate information to correctly apply return of title IV aid calculations.
Show full finding ▾Hide full finding ▴Finding 2025-003: Return of Title IV Funds - Significant Deficiency Repeat Finding: 2024-003 ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2024 - June 30, 2025 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: 34 Code of Federal Regulations (CFR) 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Context: There were 67 students who withdrew during the fiscal year and were subject to the applicable testing requirements. From this population, 7 students were selected for testing. The sample was not statistically valid. Condition: For three students tested, the semester parameters utilized by the College were inaccurate. As a result, the use of an incorrect total number of days caused the amounts required to be returned under Title IV to be either understated or overstated, and similarly affected the calculation of a post-withdrawal disbursement for one student. Cause: The College had turnover in staffing within the financial aid department during the year. The College incorrectly input the number of days in the spring semester used for the return of title IV calculation causing the College to over refund students. Effect: The amounts refunded to the Department of Education may be incorrect. Questioned Costs: $61 Context: There were 67 students who withdrew during the fiscal year and were subject to the applicable testing requirements. From this population, 7 students were selected for testing. The sample was not statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: The College acknowledges and concurs with the finding. The College is now contracting with FA Solutions to assist with student financial aid reporting. FA Solutions is considered an expert 3rd party service provider and the College will ensure that they have the appropriate information to correctly apply return of title IV aid calculations.
Views of Responsible Officials and Planned Corrective Actions: The College acknowledges and concurs with the finding. The College is now contracting with FA Solutions to assist with student financial aid reporting. FA Solutions is considered an expert 3rd party service provider and the College will ensure that they have the appropriate information to correctly apply return of title IV aid calculations.
2024-003
The College's fiscal year 2024 single audit reporting package was not submitted within the required timeframe. Cause: The College had turnover in staffing, along with issues with liquidity that led to the College holding the report until they had resolution of definitive agreement with Villanova University. Effect: The single audit reporting package was submitted weeks after the deadline of 9 months after the year end of the fiscal year. Questioned Costs: None. Recommendation: To ensure compliance with Uniform Guidance, the College should establish policies and procedures over the submission of the single audit reporting package. Management Response: The College acknowledges and concurs with the finding. The College is committed to submitting the single audit reporting package within the required timeframe in the future.
Show full finding ▾Hide full finding ▴Finding 2025-004: Late filing of Single Audit Reporting Package- Significant Deficiency Federal Program: Student Financial Assistance Cluster Award Year: July 1, 2024 - June 30, 2025 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: According to the requirements of Title 2 U.S. CFR Part 200.512, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the single audit reporting package must be submitted the earlier of 30 days after receipt of the auditors' report, or 9 months after the end of the fiscal year. Condition: The College's fiscal year 2024 single audit reporting package was not submitted within the required timeframe. Cause: The College had turnover in staffing, along with issues with liquidity that led to the College holding the report until they had resolution of definitive agreement with Villanova University. Effect: The single audit reporting package was submitted weeks after the deadline of 9 months after the year end of the fiscal year. Questioned Costs: None. Recommendation: To ensure compliance with Uniform Guidance, the College should establish policies and procedures over the submission of the single audit reporting package. Management Response: The College acknowledges and concurs with the finding. The College is committed to submitting the single audit reporting package within the required timeframe in the future.
Views of Responsible Officials and Planned Corrective Actions: The College acknowledges and concurs with the finding. The College is committed to submitting the single audit reporting package within the required timeframe in the future.
FAC accepted this audit on May 16, 2025 — management decision was due November 16, 2025.
For one withdrawn student, the College erroneously reported the effective date of the withdrawal. For one withdrawn student, there was no record found on NSLDS and the withdrawn status was not reported. For two graduated students, the status was reported incorrectly and not corrected in subsequent reporting files. For three students, the college did not report their status to NSLDS within the 60 day threshold. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of the withdrawn students to be human error. The College noted the inaccurate reporting of the students in the 5-year program and nonstandard terms to be an issue with their reporting policy in place for this particular program and will update the policy moving forward. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related process to accommodate both the internal enrollment polices and required reporting statuses, and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
Show full finding ▾Hide full finding ▴Finding 2024-001: Enrollment Reporting - Material Weakness Repeat Finding: 2023-001 ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program Award Year: July 1, 2023 - June 30, 2024 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (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. Condition: For one withdrawn student, the College erroneously reported the effective date of the withdrawal. For one withdrawn student, there was no record found on NSLDS and the withdrawn status was not reported. For two graduated students, the status was reported incorrectly and not corrected in subsequent reporting files. For three students, the college did not report their status to NSLDS within the 60 day threshold. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of the withdrawn students to be human error. The College noted the inaccurate reporting of the students in the 5-year program and nonstandard terms to be an issue with their reporting policy in place for this particular program and will update the policy moving forward. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related process to accommodate both the internal enrollment polices and required reporting statuses, and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
Management Response: The College acknowledges and concurs with the finding. The College is in the process of implementing changes to the student information systems and related process to accommodate both the internal enrollment polices and required reporting statuses, and enhances monitoring processes to ensure the integrity and punctuality of data reported to the NSLDS.
2023-001
Of the sixty students tested for eligibility, three students did not meet satisfactory academic progress. The College was not able to provide the academic probation warning or Academic Action Plan that was sent to these students in line with the College's policy. The sample was not a statistically valid sample. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: If the College is not following their policies and procedures for determining student eligibility of Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to continue participating in the Title IV program. Questioned Costs: None. Recommendation: It is recommended that the school designate an employee within the financial aid department to be responsible for monitoring academic progress and following the procedures stated within the College's Academic Progress Policy when a student does not meet the minimum standards. Management Response: The College concurs with the finding and is in the process of implementing a policy when satisfactory academic progress is run, students will be notified via mail or email of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
Show full finding ▾Hide full finding ▴Finding 2024-002: Eligibility - Satisfactory Academic Progress - Significant Deficiency Repeat Finding: 2023-002 ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Award Year: July 1, 2023 - June 30, 2024 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: To begin and to continue to participate in any Title IV, the Higher Education Act of 1965 (HEA) program, an institution shall demonstrate to the Secretary that the institution is capable of adequately administering that program under each of the standards established under 34 CFR 668.16. One of these standards states that for purposes of determining student eligibility for assistance under a Title IV, HEA program, the institution must establish, publish, and apply reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory academic progress in his or her educational program. Condition: Of the sixty students tested for eligibility, three students did not meet satisfactory academic progress. The College was not able to provide the academic probation warning or Academic Action Plan that was sent to these students in line with the College's policy. The sample was not a statistically valid sample. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: If the College is not following their policies and procedures for determining student eligibility of Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to continue participating in the Title IV program. Questioned Costs: None. Recommendation: It is recommended that the school designate an employee within the financial aid department to be responsible for monitoring academic progress and following the procedures stated within the College's Academic Progress Policy when a student does not meet the minimum standards. Management Response: The College concurs with the finding and is in the process of implementing a policy when satisfactory academic progress is run, students will be notified via mail or email of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
Management Response: The College concurs with the finding and is in the process of implementing a policy when satisfactory academic progress is run, students will be notified via mail or email of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
2023-002
For one student selected for testing, the return of Title IV funding was not returned within 45 days of the date that it was determined that the student withdrew. For one student tested, the semester parameters utilized by the College were inaccurate. The College originally determined that the student had completed less than 60% of the semester and a refund was required. However, a return was not required based on the student's actual semester length. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The amounts refunded to the Department of Education may be incorrect. The College was also in possession of funds belonging to the federal government longer than allowed. Questioned Costs: $1,967 Context: There were a total of 19 students who withdrew during the year that received Title IV aid. There was only one student that the College determined to require a return of Title IV funds. There was also one student who was noted to not have a return of funds who did require a return of funds based on testing, resulting in questioned costs. The sample was not considered statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: Going forward, all students who withdraw from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
Show full finding ▾Hide full finding ▴Finding 2024-003: Return of Title IV Funds - Significant Deficiency Repeat Finding: 2023-003 ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2023 - June 30, 2024 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: For one student selected for testing, the return of Title IV funding was not returned within 45 days of the date that it was determined that the student withdrew. For one student tested, the semester parameters utilized by the College were inaccurate. The College originally determined that the student had completed less than 60% of the semester and a refund was required. However, a return was not required based on the student's actual semester length. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The amounts refunded to the Department of Education may be incorrect. The College was also in possession of funds belonging to the federal government longer than allowed. Questioned Costs: $1,967 Context: There were a total of 19 students who withdrew during the year that received Title IV aid. There was only one student that the College determined to require a return of Title IV funds. There was also one student who was noted to not have a return of funds who did require a return of funds based on testing, resulting in questioned costs. The sample was not considered statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: Going forward, all students who withdraw from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
Management Response: Going forward, all students who withdraw from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
2023-003
Of the forty disbursements to students tested, one disbursement tested had a difference when reconciling the student account statement to the COD system. The sample was not a statistically valid sample. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The potential exists that an error could occur in the financial records and not be detected within a timely manner resulting in variances between the College's records and the Department of Education records. Questioned Costs: $494 Recommendation: The College should perform monthly reconciliations of the College’s financial records compared to the Direct Loan system records on a timely basis and they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify and correct all errors to ensure compliance with federal regulations. Management Response: Management concurs with the finding and will reconcile the College’s disbursement records with the federal COD system and correct all errors on a monthly basis.
Show full finding ▾Hide full finding ▴Finding 2024-004: Disbursements to Students - Significant Deficiency ALN: 84.268 Federal Direct Loan Program Award Year: July 1, 2023 - June 30, 2024 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: 34 CFR 668.164 requires that institutions must ensure that disbursements reported to the Common Origination and Disbursement (COD) system accurately reflect the amounts posted to students' accounts. Regular reconciliation between the COD system and institutional financial records is required to identify and correct discrepancies, thereby maintaining compliance with federal regulations. Failure to perform these reconciliations can lead to inaccurate financial reporting and potential noncompliance with Title IV requirements. Condition: Of the forty disbursements to students tested, one disbursement tested had a difference when reconciling the student account statement to the COD system. The sample was not a statistically valid sample. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The potential exists that an error could occur in the financial records and not be detected within a timely manner resulting in variances between the College's records and the Department of Education records. Questioned Costs: $494 Recommendation: The College should perform monthly reconciliations of the College’s financial records compared to the Direct Loan system records on a timely basis and they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify and correct all errors to ensure compliance with federal regulations. Management Response: Management concurs with the finding and will reconcile the College’s disbursement records with the federal COD system and correct all errors on a monthly basis.
Management Response: Management concurs with the finding and will reconcile the College’s disbursement records with the federal COD system and correct all errors on a monthly basis.
FAC accepted this audit on April 10, 2024 — management decision was due October 10, 2024.
For 3 withdrawn students, the College erroneously reported the effective date of the withdrawal. For 2 students in a 5-year program, which included a bachelor's and master's program, the College did not report the student's graduation date from the bachelor's degree program and utilized the start date of the bachelor's degree program as the start date of the master's program, resulting in inaccurate reporting. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of the withdrawn students to be human error. The College noted the inaccurate reporting of the students in the 5-year program to be an issue with their reporting policy in place for this particular program and will update the policy moving forward. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Currently, the College marks students withdrawn on the date the withdrawal is officially processed in the system, indicating their last date of attendance. The withdrawal policy will be updated to indicate that the withdraw date to be reported for all students withdrawing at either the program or campus level should be processed as the "last date of attendance". In the case of the 5- year program (4+1 internally), we currently do not officially "enroll" a student into the master's program until their bachelor's degree is conferred. The official admit date will be updated to reflect the term a student enters the master's program officially, which will begin after the conferral of their bachelor's degree. Our policy and processes for the 4+1 program will be updated to reflect this change.
Show full finding ▾Hide full finding ▴Finding 2023-001: Enrollment Reporting - Material Weakness ALN: 84.268 Federal Direct Loan Program, 84.063 Federal Pell Grant Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan 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. Condition: For 3 withdrawn students, the College erroneously reported the effective date of the withdrawal. For 2 students in a 5-year program, which included a bachelor's and master's program, the College did not report the student's graduation date from the bachelor's degree program and utilized the start date of the bachelor's degree program as the start date of the master's program, resulting in inaccurate reporting. The sample, which consisted of 25 students, was not a statistically valid sample. Cause: The College noted the discrepancies in reporting of the withdrawn students to be human error. The College noted the inaccurate reporting of the students in the 5-year program to be an issue with their reporting policy in place for this particular program and will update the policy moving forward. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verifystudent enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that the College review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Currently, the College marks students withdrawn on the date the withdrawal is officially processed in the system, indicating their last date of attendance. The withdrawal policy will be updated to indicate that the withdraw date to be reported for all students withdrawing at either the program or campus level should be processed as the "last date of attendance". In the case of the 5- year program (4+1 internally), we currently do not officially "enroll" a student into the master's program until their bachelor's degree is conferred. The official admit date will be updated to reflect the term a student enters the master's program officially, which will begin after the conferral of their bachelor's degree. Our policy and processes for the 4+1 program will be updated to reflect this change.
Currently, the College marks students withdrawn on the date the withdrawal is officially processed in the system, indicating their last data of attendance. The withdrawal policy will be updated to indicate that the withdraw date to be reported for all students withdrawing at either the program or campus level should be processed as the "last date of attendance". In the case of the 5-year program (4+1 internally), we currently do not officially "enroll" a student into the master's program until their bachelor's degree is conferred. The official admit date will be updated to reflect the term a student enters the master's program officially, which will begin after the conferral of their bachelor's degree. Our policy and processes for the 4+1 program will be updated to reflect this change.
Of the 40 students tested for eligibility, 7 students did not meet satisfactory academic progress. For 6 of those students, the College was not able to provide the academic probation warning or Academic Action Plan that was sent to these students in line with the College's policy. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: If the College is not following their policies and procedures for determining student eligibility of Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to continue participating in the Title IV program. Questioned Costs: None. Recommendation: It is recommended that the College designate an employee within the financial aid department to be responsible for monitoring academic progress and following the procedures stated within the College's Academic Progress Policy when a student does not meet the minimum standards. Management Response: When SAP is run in the spring, students will be notified of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
Show full finding ▾Hide full finding ▴Finding 2023-002: Eligibility - Satisfactory Academic Progress - Significant Deficiency ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: To begin and to continue to participate in any Title IV, HEA program, an institution shall demonstrate to the Secretary that the institution is capable of adequately administering that program under each of the standards established under 34 CFR 668.16. One of these standards states that for purposes of determining student eligibility for assistance under a title IV, HEA program, the institution must establish, publish, and apply reasonable standards for measuring whether an otherwise eligible student is maintaining satisfactory academic progress in his or her educational program. Condition: Of the 40 students tested for eligibility, 7 students did not meet satisfactory academic progress. For 6 of those students, the College was not able to provide the academic probation warning or Academic Action Plan that was sent to these students in line with the College's policy. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: If the College is not following their policies and procedures for determining student eligibility of Title IV aid, there could be unallowable aid disbursed which could affect the College's ability to continue participating in the Title IV program. Questioned Costs: None. Recommendation: It is recommended that the College designate an employee within the financial aid department to be responsible for monitoring academic progress and following the procedures stated within the College's Academic Progress Policy when a student does not meet the minimum standards. Management Response: When SAP is run in the spring, students will be notified of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
When SAP is run in the spring, students will be notified of their academic standing. Students who are suspended will have an opportunity to appeal their suspension. If the appeal of suspension is approved, students will meet with their academic advisor to be placed on an academic plan. The academic plan must be signed by both the student and advisor. The academic plan must be submitted to the Office of Financial Aid via the teams. A financial aid hold will be placed on the student's account until the signed academic plan is received. Once received, the Office of Financial Aid will remove the hold so the student can be awarded.
For one student selected for testing, the return of Title IV funding was not returned within 45 days of the date that it was determined that the student withdrew. For one student tested, the withdrawal date utilized by the College was inaccurate. The College originally determined that the student had completed 60% of the semester and a refund was not required. However, a return was required based on the student's actual withdrawal date. The College did ultimately return the funds. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The amounts refunded to the Department of Education may be incorrect. The College was also in possession of funds belonging to the federal government longer than allowed. Questioned Costs: $4,675 Context: There were a total of 19 students who withdrew during the year that received Title IV aid. There was only one student that the College determined to require a return of Title IV funds. There was also 1 student who was noted to not have a return of funds who actually did require a return of funds based on testing, resulting in questioned costs. The sample was not considered statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
Show full finding ▾Hide full finding ▴Finding 2023-003: Return of Title IV Funds – Significant Deficiency ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: For one student selected for testing, the return of Title IV funding was not returned within 45 days of the date that it was determined that the student withdrew. For one student tested, the withdrawal date utilized by the College was inaccurate. The College originally determined that the student had completed 60% of the semester and a refund was not required. However, a return was required based on the student's actual withdrawal date. The College did ultimately return the funds. Cause: The College had turnover in staffing within the financial aid department causing these procedures to be missed. Effect: The amounts refunded to the Department of Education may be incorrect. The College was also in possession of funds belonging to the federal government longer than allowed. Questioned Costs: $4,675 Context: There were a total of 19 students who withdrew during the year that received Title IV aid. There was only one student that the College determined to require a return of Title IV funds. There was also 1 student who was noted to not have a return of funds who actually did require a return of funds based on testing, resulting in questioned costs. The sample was not considered statistically valid. Recommendation: The College should modify its procedures for refunding awards to ensure proper date computations, as well as disbursing refunds in a timely manner. Management Response: Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
Going forward, all students who withdrawal from the College will be forwarded to the financial aid team to review whether a student is still eligible for the full funding of the specific semester in question or whether funding needs to be returned based on the withdrawal date. If it is deemed that funds need to be returned, the Bursar will provide the financial aid team with a copy of the student charges for that period and the Registrar will provide proof of the withdrawal date and the financial aid team will determine the amount of funding that needs to be returned. Financial Aid will then complete the return through the student's account and notify the Controller and VP of Finance and Administration to process the return to G5.
FAC accepted this audit on February 2, 2022 — management decision was due August 2, 2022.
For 1 of 15 students tested, supporting documents did not match the ISIR and there was no correction made by the school in the verification process. Questioned Costs: The total need-based Federal aid disbursed to the student during fiscal year 2021 was $19,845. Context: The total need-based Federal aid disbursed to the 15 students tested during fiscal year 2021 was $242,559. A total of 89 students were selected for verification during fiscal year 2021. The sample was not considered statistically valid. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendations: We recommend that the College put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Action: The College onboarded new leadership in the Financial Aid operation. A quality assurance plan was instituted by the Director of Financial aid to review federal verification outcomes for all completed verifications and to confirm financial aid award offers for all Title IV recipients effective August 1, 2021. Title IV aid is not disbursed for students who are selected for verification until the account is verified by the Director of Financial Aid and all required corrections are received and imported into the student record. A verification checklist is completed, all required documentation is confirmed as received, all verifiable items are double-checked for accuracy before updating the student record from unverified to verified status. After verification is completed, all verified accounts undergo a review process by the Director of Financial Aid. The subsequent reviews establish an internal control to confirm that the information used to calculate the student's eligibility was reported on the ISIR accurately and sent to CPS if a correction was required. Financial aid packages are audited prior to disbursement to confirm direct loan eligibility based on unmet need, total credits earned, and cost of attendance. The awards for students are reviewed at the start of each semester and after the drop and add period.
Show full finding ▾Hide full finding ▴Finding 2021-002 - Verification CFDA: 84.268 Federal Direct Student Loans, 84.063 Federal Pell Grant Program, 84.007 Federal Supplemental Educational Opportunity Grants Year: 2020-2021 Federal Agency: U.S. Department of Education Federal Award Number: N/A Criteria: Title IV regulations note that the institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. The institution shall require applicants to verify any information used to calculate an applicant's EFC that the institution has reason to believe is inaccurate (34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4). Condition: For 1 of 15 students tested, supporting documents did not match the ISIR and there was no correction made by the school in the verification process. Questioned Costs: The total need-based Federal aid disbursed to the student during fiscal year 2021 was $19,845. Context: The total need-based Federal aid disbursed to the 15 students tested during fiscal year 2021 was $242,559. A total of 89 students were selected for verification during fiscal year 2021. The sample was not considered statistically valid. Cause: The College does not have a system of proper controls and procedures in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Effect: Students could be awarded Federal funds that they are not eligible for or not be awarded the full amount of Federal funds that they would otherwise have been eligible for. Recommendations: We recommend that the College put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Views of Responsible Officials and Planned Corrective Action: The College onboarded new leadership in the Financial Aid operation. A quality assurance plan was instituted by the Director of Financial aid to review federal verification outcomes for all completed verifications and to confirm financial aid award offers for all Title IV recipients effective August 1, 2021. Title IV aid is not disbursed for students who are selected for verification until the account is verified by the Director of Financial Aid and all required corrections are received and imported into the student record. A verification checklist is completed, all required documentation is confirmed as received, all verifiable items are double-checked for accuracy before updating the student record from unverified to verified status. After verification is completed, all verified accounts undergo a review process by the Director of Financial Aid. The subsequent reviews establish an internal control to confirm that the information used to calculate the student's eligibility was reported on the ISIR accurately and sent to CPS if a correction was required. Financial aid packages are audited prior to disbursement to confirm direct loan eligibility based on unmet need, total credits earned, and cost of attendance. The awards for students are reviewed at the start of each semester and after the drop and add period.
Finding No. 2021-002---Verification Statement of Condition: For 1 of 15 students tested, supporting documents did not match the ISIR and there was no correction made by the school in the verification process.Recommendation: We recommend that the College put proper policies and controls in place to ensure that all aspects of the verification process are completed prior to disbursing Federal funds to students. Corrective Action: The Director of Financial Aid is responsible for the oversight of the entire Financial Aid Department. The College onboarded new leadership in the Director of Financial Aid position. A quality assurance plan was instituted by the Director of Financial aid to review federal verification outcomes for all completed verifications and to confirm financial aid award offers for all Title IV recipients effective August 1, 2021. Title IV aid is not disbursed for students who are selected for verification until the account is verified and all required corrections are received and imported into the student record. A verification checklist is completed, all required documentation is confirmed as received, all verifiable items are double-checked for accuracy before updating the student record from unverified to verified status. After verification is completed, all verified accounts undergo a review process. The subsequent reviews establish an internal control to confirm that the information used to calculate the student?s eligibility was reported on the ISIR accurately and sent to CPS if a correction was required. Financial aid packages are audited prior to disbursement to confirm direct loan eligibility based on unmet need, total credits earned, and cost of attendance. The awards for students are reviewed at the start of each semester and after the drop and add period.
Finding 2021-003 - Enrollment Reporting CFDA: 84.268 Federal Direct Student Loans Year: 2020-2021 Federal Agency: U.S. Department of Education Federal Award Number: N/A Repeat of Prior Year Finding 2020-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.Condition/Context: The change in student status for 4 of 16 students tested was not reported accurately to the National Student Loan Data System (NSLDS), and the change in student status for 1 of 16 students was not reported timely within 30 days or included in a response to a roster file within 60 days. The College did submit a report to correct the errors in enrollment reporting once discovered. The sample was not a statistically valid sample. Questioned Costs: None. Cause: The College went through a change in administration during fiscal year 2021 and certain activities were not completed by the responsible parties. In addition, certain students had no FICE code in the NSLDS system which the College believes to be the cause for a student to not be reported to NSC at all, resulting in no record of attendance at the College for certain students. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendations: We recommend the College review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by the regulations described above. Views of Responsible Officials and Planned Corrective Action: In the Fall 2021 term, the Registrar implemented a step in their reporting process that allows the College to quality check NSC reports prior to their submissions. During the quality check step, the Registrar ensures that all students have a code for their FICE. If a code is missing, it is manually entered. Once the review occurs, the information is submitted to NSC. The Registrar updates the reporting dates to NSC based on the start and end times of each session during a term. A first of term report is submitted within 30 days after the start of term. A subsequent of term report is submitted mid-term, after the end of session I and start of session II courses. An end of term report is submitted after final grades have been posted for the term.
Show full finding ▾Hide full finding ▴Finding 2021-003 - Enrollment Reporting CFDA: 84.268 Federal Direct Student Loans Year: 2020-2021 Federal Agency: U.S. Department of Education Federal Award Number: N/A Repeat of Prior Year Finding 2020-002 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.Condition/Context: The change in student status for 4 of 16 students tested was not reported accurately to the National Student Loan Data System (NSLDS), and the change in student status for 1 of 16 students was not reported timely within 30 days or included in a response to a roster file within 60 days. The College did submit a report to correct the errors in enrollment reporting once discovered. The sample was not a statistically valid sample. Questioned Costs: None. Cause: The College went through a change in administration during fiscal year 2021 and certain activities were not completed by the responsible parties. In addition, certain students had no FICE code in the NSLDS system which the College believes to be the cause for a student to not be reported to NSC at all, resulting in no record of attendance at the College for certain students. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendations: We recommend the College review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by the regulations described above. Views of Responsible Officials and Planned Corrective Action: In the Fall 2021 term, the Registrar implemented a step in their reporting process that allows the College to quality check NSC reports prior to their submissions. During the quality check step, the Registrar ensures that all students have a code for their FICE. If a code is missing, it is manually entered. Once the review occurs, the information is submitted to NSC. The Registrar updates the reporting dates to NSC based on the start and end times of each session during a term. A first of term report is submitted within 30 days after the start of term. A subsequent of term report is submitted mid-term, after the end of session I and start of session II courses. An end of term report is submitted after final grades have been posted for the term.
Finding No. 2021-003---Enrollment Reporting Statement of Condition: The change in student status for 4 of 16 students tested were not reported accurately to the National Student Loan Data System (NSLDS), and the change in student status for 1 of 16 students was not reported timely within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Recommendation: The audit firm recommends the College review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by the regulations described above. Corrective Action: The Registrar is responsible for the enrollment reporting that is completed by Rosemont College to the National Student Clearinghouse. In the Fall 2021 term, the Registrar?s Office implemented a step in our reporting process that allows us to quality check NSC reports prior to their submissions. During the quality check step, we ensure that all students have a code for their FICE. If a code is missing, it is manually entered. Once the review occurs, the information is submitted to NSC. The Registrar?s Office updated the reporting dates to NSC based on the start and end times of each session during a term. A first of term report is submitted within 30 days after the start of term. A subsequent of term report is submitted mid-term, after the end of session I and start of session II courses. An end of term report is submitted after final grades have been posted for the term.
2020-002
FAC accepted this audit on April 22, 2021 — management decision was due October 22, 2021.
Finding 2020-002: Enrollment Reporting CFDA: 84.268 Federal Direct Student Loans Year: 2019-2020 Federal Agency: U.S. Department of Education Federal Award Number: N/A Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 3 of 22 students tested were not reported accurately to the National Student Loan Data System (NSLDS), and the change in student status for 16 of 22 students was not reported timely within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Questioned Costs: None. Cause: The College was shut down between March and August 2020, and certain activities normally performed by the Registrar were not done during that time. In addition, certain fields were unintentionally checked in the enrollment reporting system that caused the students to be excluded from the reporting. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendations: We recommend the College review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by the regulations described above. Views of Responsible Officials and Planned Corrective Action: The Registrar is responsible for the enrollment reporting that is completed by Rosemont College to the National Student Clearinghouse. In regard to the number of students that were not reported within 30 days, this took place during the pandemic and the Registrar at that point in time did not follow the established procedures during the period of time that the College was shut down due to the pandemic. There has since been a change in personnel within the Registrar position and the new Registrar has been provided with the appropriate training by a software consultant that we contracted to ensure we are meeting the established reporting requirements.
Show full finding ▾Hide full finding ▴Finding 2020-002: Enrollment Reporting CFDA: 84.268 Federal Direct Student Loans Year: 2019-2020 Federal Agency: U.S. Department of Education Federal Award Number: N/A Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: The change in student status for 3 of 22 students tested were not reported accurately to the National Student Loan Data System (NSLDS), and the change in student status for 16 of 22 students was not reported timely within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Questioned Costs: None. Cause: The College was shut down between March and August 2020, and certain activities normally performed by the Registrar were not done during that time. In addition, certain fields were unintentionally checked in the enrollment reporting system that caused the students to be excluded from the reporting. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendations: We recommend the College review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by the regulations described above. Views of Responsible Officials and Planned Corrective Action: The Registrar is responsible for the enrollment reporting that is completed by Rosemont College to the National Student Clearinghouse. In regard to the number of students that were not reported within 30 days, this took place during the pandemic and the Registrar at that point in time did not follow the established procedures during the period of time that the College was shut down due to the pandemic. There has since been a change in personnel within the Registrar position and the new Registrar has been provided with the appropriate training by a software consultant that we contracted to ensure we are meeting the established reporting requirements.
Finding No. 2020-002---Enrollment Reporting Statement of Condition: The change in student status for 3 of 22 students tested were not reported accurately to the National Student Loan Data System (NSLDS), and the change in student status for 16 of 22 students was not reported timely within 30 days or included in a response to a roster file within 60 days. The sample was not a statistically valid sample. Recommendation: The audit firm recommends the College review and revise its reporting procedures to ensure that student statuses are accurately and timely reported to NSLDS as required by the regulations described above. Corrective Action: The Registrar is responsible for the enrollment reporting that is completed by Rosemont College to the National Student Clearinghouse. In regard to the number of students that were not reported within 30 days, this took place during the pandemic and the Registrar at that point in time did not follow the established procedures during the period of time that the College was shut down due to the pandemic. There has since been a change in personnel within the Registrar position and the new Registrar has been provided with the appropriate training by a software consultant that we contracted to ensure we are meeting the established reporting requirements. For the three students that were not reported accurately, it was determined during the training, with the software consultant, that there were boxes unintentionally checked within the student information system that excluded these students from being reported. Since then, a full review of the records has been completed to determine if there were any other students that met these same criteria. In addition to that check, there were rules-based updates that were performed in the system to decrease the amount of records that were erroring out during this process. The Registrar has been provided with the appropriate training and reference documentation in April of 2021, to execute this critical step on the regularly scheduled basis to ensure these mistakes are no longer made. Since the training has taken place there have been minimal errors received when records have been reported.
Finding 2020-003: Return of Title IV Funds CFDA: 84.268 Federal Direct Student Loans Year: 2019-2020 Federal Agency: U.S. Department of Education Federal Award Number: N/A Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for one of the students tested was not returned within 45 days from the withdrawal date. In addition, the College had difficulty providing a complete list of students that withdrew during the fiscal year. The sample was not a statistically valid sample. Questioned Costs: $1,531 Cause: The student took an approved Leave of Absence in Fall 2019, and the leave was extended due to the COVID-19 pandemic until December 31, 2020. When the student did not return to the College for the Spring 2021 semester, the financial aid office was not aware that a calculation needed to be performed. Effect: The College was in possession of funds belonging to the federal government longer than allowed. Recommendations: The College should increase emphasis on timely communication between the registrar and financial aid office and the processing of refund transactions. Views of Responsible Officials and Planned Corrective Action: Rosemont concurs with the finding and believes this to be an isolated incident that was caused by the shutdown of the pandemic. The Financial Aid Office is responsible for processing the R2T4 calculations in a timely manner. There is a new Registrar in place and the Financial Aid Office has emphasized the importance of communicating when students drop or do not return from a leave of absence. The College will continue to follow the established procedures.
Show full finding ▾Hide full finding ▴Finding 2020-003: Return of Title IV Funds CFDA: 84.268 Federal Direct Student Loans Year: 2019-2020 Federal Agency: U.S. Department of Education Federal Award Number: N/A Criteria: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: The federal aid refunds for one of the students tested was not returned within 45 days from the withdrawal date. In addition, the College had difficulty providing a complete list of students that withdrew during the fiscal year. The sample was not a statistically valid sample. Questioned Costs: $1,531 Cause: The student took an approved Leave of Absence in Fall 2019, and the leave was extended due to the COVID-19 pandemic until December 31, 2020. When the student did not return to the College for the Spring 2021 semester, the financial aid office was not aware that a calculation needed to be performed. Effect: The College was in possession of funds belonging to the federal government longer than allowed. Recommendations: The College should increase emphasis on timely communication between the registrar and financial aid office and the processing of refund transactions. Views of Responsible Officials and Planned Corrective Action: Rosemont concurs with the finding and believes this to be an isolated incident that was caused by the shutdown of the pandemic. The Financial Aid Office is responsible for processing the R2T4 calculations in a timely manner. There is a new Registrar in place and the Financial Aid Office has emphasized the importance of communicating when students drop or do not return from a leave of absence. The College will continue to follow the established procedures.
Finding No. 2020-003---Return of Title IV Funds Statement of Condition: The federal aid refunds for one of the students was not returned within 45 days from the withdrawal date. In addition, the College had difficulty providing a complete list of students that withdrew during the fiscal year. Recommendation: The College should increase emphasis on timely communication between the registrar and financial aid office and the processing of refund transactions. Corrective Action: Rosemont concurs with the finding and believes this to be an isolated incident that was caused by the shutdown of the pandemic. The Financial Aid Office is responsible for processing the R2T4 calculations in a timely manner. There is a new Registrar in place and the Financial Aid Office has emphasized the importance of communicating when students drop or do not return from a leave of absence. The College will continue to follow the established procedures.
FAC accepted this audit on March 18, 2020 — management decision was due September 18, 2020.
The College did not void/return outstanding student refund balance checks within the 240 day time frame. Questioned costs: $10,233 (outstanding checks over 240 days). Context: 13 out of 31 outstanding student refund checks as of June 30, 2019 were noted to have been outstanding for greater than 240 days. Of these 13 checks, 13 were noted as not being voided or refunded to the Department of Education in a timely manner. Cause: Absence of the review of outstanding check listing for issued financial aid disbursements. Effect: As the result of not voiding issued student refund checks outstanding for over 240 days, the college is not in compliance with the corresponding requirement of the Department of Education. Repeat Finding: Not a repeat finding. Recommendation: The College should implement a control to establish an ongoing reconciliation of the outstanding refund check listing. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Aid Cluster - Outstanding Student Refund Checks CFDA Number: 84.033 Award Period: 2018-2019 Type of Finding: Significant Deficiency in Internal Controls over Compliance and Other Matter Criteria or specific requirement: If disbursement of a student refund balance by check is not cashed, the school must return the funds no later than 240 days after the original issued check. Condition: The College did not void/return outstanding student refund balance checks within the 240 day time frame. Questioned costs: $10,233 (outstanding checks over 240 days). Context: 13 out of 31 outstanding student refund checks as of June 30, 2019 were noted to have been outstanding for greater than 240 days. Of these 13 checks, 13 were noted as not being voided or refunded to the Department of Education in a timely manner. Cause: Absence of the review of outstanding check listing for issued financial aid disbursements. Effect: As the result of not voiding issued student refund checks outstanding for over 240 days, the college is not in compliance with the corresponding requirement of the Department of Education. Repeat Finding: Not a repeat finding. Recommendation: The College should implement a control to establish an ongoing reconciliation of the outstanding refund check listing. Views of responsible officials: There is no disagreement with the audit finding.
ROSEMONT COLLEGE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2019 Department of Education Rosemont College respectfully submits the following corrective action plan for the year ended June 30, 2019. Audit period: 2019 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2019-001 Untimely Void and Refund of Outstanding Student Refund Check Recommendation: The College should implement a control to establish an ongoing reconciliation of the outstanding refund check listing.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Controller has instructed the Bursar and Accounts Payable Coordinator to make every effort to resolve outstanding Title IV refund checks within forty-five (45) days of issue. Rosemont College checks currently have a life of sixty (60) days. The following is the procedure the Accounts Payable Coordinator will follow until either a check is reissued to the student/parent or the funds are returned to the Department of Education: 1. 45 days from date of check, send student or parent letter as attached via mail notifying them that the check has not yet cleared our bank 2. 60 days from date of check, email student or parent the letter at all email addresses we have on file 3. 75 days from date of check, follow up again by email and if available by phone a. If a response is received after 1, 2 or 3, a replacement check will be issued immediately 4. 80 days from date of check, void check 5. 90 days from date of check, submit excel spreadsheet to the Controller and Director of Financial Aid for review and funds can be returned to the Department of Education if all avenues of reaching the student has been exhausted a. all communication with students and vendors will be noted on the spreadsheet that are currently in process through Accounts Payable Coordinator. Name(s) of the contact person(s) responsible for corrective action: Juliann Ewing, Bursar Planned completion date for corrective action plan: January 31, 2020 If the Department of Education has questions regarding this plan, please call Faith M. Byrne, Controller at 610-527-0200 Extension 2593. Sincerely yours, Faith M. Byrne - Controller
FAC accepted this audit on November 29, 2018 — management decision was due May 29, 2019.
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FAC accepted this audit on March 7, 2018 — management decision was due September 7, 2018.
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FAC accepted this audit on February 23, 2017 — management decision was due August 23, 2017.
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