EIN: 231627436
UEI: UEK6RNK9P1X7
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 30, 2023. 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 May 30, 2024 (819 days ago).
What is a management decision? →Certain of the College’s admissions employees received merit-based adjustments to their annual compensation which were based in part upon success in securing enrollments. Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i). Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid; and profit sharing payments so long as such payments are not provided to any person or entity engaged in student recruitment or admission activity or in making decisions regarding the award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions employees which were based in part upon success in securing enrollments. Questioned costs: None. Repeat Finding: No. Recommendation: We recommend that management review and update its annual performance review process and forms to ensure that the College is not awarding any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds. Views of Responsible Officials: The College revised the annual Performance Management Review form to expressly prohibit a performance metric for securing enrollment. All personnel have been retrained.
Show full finding ▾Hide full finding ▴Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023 Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value, other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR 668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid; and profitsharing payments so long as such payments are not provided to any person or entity engaged in student recruitment or admission activity or in making decisions regarding the award of title IV, HEA program funds. Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual compensation which were based in part upon success in securing enrollments. Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i). Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid; and profit sharing payments so long as such payments are not provided to any person or entity engaged in student recruitment or admission activity or in making decisions regarding the award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions employees which were based in part upon success in securing enrollments. Questioned costs: None. Repeat Finding: No. Recommendation: We recommend that management review and update its annual performance review process and forms to ensure that the College is not awarding any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA program funds. Views of Responsible Officials: The College revised the annual Performance Management Review form to expressly prohibit a performance metric for securing enrollment. All personnel have been retrained.
Views of Responsible Officials and Corrective Action Plan (Finding 2023-001) In the process of assessing internal controls related to the prohibition of incentive compensation for enrollment recruiting, the College determined that three admissions personnel had been assigned an individual goal for securing enrollment. The enrollment goal was one of multiple criteria used to determine an overall performance rating that was the basis for merit increases awarded on July 1, 2022. The total merit increases awarded to certain of the College's admissions employees was $2,541, which were based in part upon success in securing enrollments. The College was not aware of the prohibition on merit-based adjustments based in any part, directly or indirectly, upon success in securing enrollments. The College has revised the annual Performance Management Review form to expressly prohibit a performance metric for securing enrollment. All personnel have been re-trained. For questions, please reach out to Elizabeth M. Krapp, Vice President, Finance and Administration at emkrapp@peirce.edu or Brad Hodge, Vice President, Enrollment Management & Student Services at bkhodge@peirce.edu.
FAC accepted this audit on May 24, 2018 — management decision was due November 24, 2018.
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