EIN: 240795441
UEI: EVNRN16ZFLK4
Audited by: Kohanski and Company PC
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 24, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 24, 2026 (9 days ago).
What is a management decision? →For two students out of twenty-five selected for testing, receipt of Title IV funds created an overpayment to the students' account which was returned to the students, but not in accordance with the criteria noted above. Cause: Manamement of the College has implemented procedures to ensure credit balances are returned within the required time frame. these students were identified and corrected after the procedures were implemented. Effect: The College was not in compliance with the requirements and students did not timely receive the Title IV funds to which they were entitled.
Show full finding ▾Hide full finding ▴Criteria: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class or a payment period if the credit balance occurred on or before that day, or (2) the balance occured that was after the first day of class. Condition: For two students out of twenty-five selected for testing, receipt of Title IV funds created an overpayment to the students' account which was returned to the students, but not in accordance with the criteria noted above. Cause: Manamement of the College has implemented procedures to ensure credit balances are returned within the required time frame. these students were identified and corrected after the procedures were implemented. Effect: The College was not in compliance with the requirements and students did not timely receive the Title IV funds to which they were entitled.
The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and corrected any findings. As a means of maintaining compliance under the Heightened Cash Monitoring 1 Payment Method (HCM1) as described under 34 C.F.R. § 668.162(d)(1), Keystone first makes disbursements to eligible students and parents and pays any remaining credit balances before it requests or receives funds for the amount of those disbursements from the Department. The College’s practices and internal controls for Title IV, HEA program funds received from the Department reflect the compliance criteria as required.
2024-002
FAC accepted this audit on February 27, 2025 — management decision was due August 27, 2025.
For one student out of twenty -five tested, receipt of Title IV funds created an over payment to the students' account which was returned to the student, but not in accordance with the criteria noted above. Cause: Management of the College has implemented procedures to ensure credit balances are returned within the required time frame. This student was identified and corrected after the procedures were implemented. Effect: The College was not in compliance with the requirements and students did not timely receive the Title IV funds to which they were entitled.
Show full finding ▾Hide full finding ▴Criteria: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authroized charges assessed to the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class or a payment period if the credit balance occurred on or before that day, or (2) the balance occured if that was after the first day of class. Condition: For one student out of twenty -five tested, receipt of Title IV funds created an over payment to the students' account which was returned to the student, but not in accordance with the criteria noted above. Cause: Management of the College has implemented procedures to ensure credit balances are returned within the required time frame. This student was identified and corrected after the procedures were implemented. Effect: The College was not in compliance with the requirements and students did not timely receive the Title IV funds to which they were entitled.
Management has strengthened controls and trained staff to ensure compliance with cash management practices for future federal awards.
2023-004
During the year ended May 31, 2024 the College disbursed $63,000of SEOG funds to students, but drew down their entire authorized amount of $123,626 resulting in an overdraw of $60,626. Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College was not in compliance with the HCM1 drawdown payment method.
Show full finding ▾Hide full finding ▴Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education. Condition: During the year ended May 31, 2024 the College disbursed $63,000of SEOG funds to students, but drew down their entire authorized amount of $123,626 resulting in an overdraw of $60,626. Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College was not in compliance with the HCM1 drawdown payment method.
Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College has also strengthened controls and trained staff to ensure compliance with cash management practices for future federal awards.
For one student out of five selected for testing, the amount of the Title IV refund was calculated incorrectly, resuling in an underpayment of PELL funds of $124. Cause: The College did not apply the correct end date for the semester when performing the calculations. Effect: The College did not refund the correct amount of PELL funds to the Title IV program.
Show full finding ▾Hide full finding ▴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 out of five selected for testing, the amount of the Title IV refund was calculated incorrectly, resuling in an underpayment of PELL funds of $124. Cause: The College did not apply the correct end date for the semester when performing the calculations. Effect: The College did not refund the correct amount of PELL funds to the Title IV program.
Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the appropriate Title IV program in accordance with federal regulations.
FAC accepted this audit on August 30, 2024 — management decision was due March 2, 2025.
For four students out of forty tested, receipt of Title IV funds created an over payment to the students' account which was not returned to the student in accordance with the criteria noted above. Cause: Management of the College incorrectly interpreted the requirements. Effect: The College was not in compliance with the requirements and students did not timely receive the Title IV funds to which they were entitled.
Show full finding ▾Hide full finding ▴Criteria: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authroized charges assessed to the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class or a payment period if the credit balance occurred on or before that day, or (2) the balance occured if that was after the first day of class. Condition: For four students out of forty tested, receipt of Title IV funds created an over payment to the students' account which was not returned to the student in accordance with the criteria noted above. Cause: Management of the College incorrectly interpreted the requirements. Effect: The College was not in compliance with the requirements and students did not timely receive the Title IV funds to which they were entitled.
Administration will implement appropriate controls and train staff to ensure compliance with cash management practices for future federal awards.
FAC accepted this audit on May 20, 2024 — management decision was due November 20, 2024.
During the year, the College disbursed $43,983 of SEOG funds to students but drew down their entire authorized amount of $123,626 resulting in an overdraw of $79,643. Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education (DOE). Context: A review of the entire population of drawdowns for the Student Financial Aid cluster for the entire year was performed and as such, the sample is statistically valid. Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College was not in compliance with the HCM1 drawdown payment method. Questioned costs: $79,643. Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the HCM payment method. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Condition: During the year, the College disbursed $43,983 of SEOG funds to students but drew down their entire authorized amount of $123,626 resulting in an overdraw of $79,643. Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education (DOE). Context: A review of the entire population of drawdowns for the Student Financial Aid cluster for the entire year was performed and as such, the sample is statistically valid. Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College was not in compliance with the HCM1 drawdown payment method. Questioned costs: $79,643. Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the HCM payment method. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
The College is reviewing processes in place with third party financial aid servicer and internal policies to implement controls over compliance
2021-006
The College did not fully comply with the requirements outlined in the award that requires funds to be disbursed within 3 days of the drawdown from G5. The College follows the cash basis of accounting as described in the footnotes to the schedule of expenditures of federal awards, and during the year, it charged $116,037 prior to drawdown and $83,561 subsequent to drawdown. Criteria: CRRSAA HEERF II and ARP HEERF II require that Institutional Aid Portions should be disbursed within 3 calendar days of the drawdown from G5. Cause: Personnel were not fully aware of the timeframe required for funds to be spend under the award agreement. Effect: The College was not in compliance with the Cash Management compliance requirement. Questioned costs: Not Applicable. Recommendation: The College should take action to ensure staff are trained to be knowledgeable of all requirements under federal awards it receives. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Condition: The College did not fully comply with the requirements outlined in the award that requires funds to be disbursed within 3 days of the drawdown from G5. The College follows the cash basis of accounting as described in the footnotes to the schedule of expenditures of federal awards, and during the year, it charged $116,037 prior to drawdown and $83,561 subsequent to drawdown. Criteria: CRRSAA HEERF II and ARP HEERF II require that Institutional Aid Portions should be disbursed within 3 calendar days of the drawdown from G5. Cause: Personnel were not fully aware of the timeframe required for funds to be spend under the award agreement. Effect: The College was not in compliance with the Cash Management compliance requirement. Questioned costs: Not Applicable. Recommendation: The College should take action to ensure staff are trained to be knowledgeable of all requirements under federal awards it receives. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding.
College will implement training for staff to ensure compliance with future federal awards
It was noted during the audit that the amount of Pell awards granted to students was not accurately reported on the College’s annual Fiscal Operations Report and Application to Participate (FISAP). Criteria: Non-federal entities are required to submit the FISAP electronically, on an annual basis, for its campus-based programs to report expenditures in the previous award year. Cause: The Chief Financial Officer reported the incorrect amount of Pell awards disbursed to students. Effect: Inaccurate report was filed. Questioned costs: Not applicable. Views of Responsible Officials and Planned Corrective Actions: The College should establish a procedure that requires a separate review of the FISAP prior to submission. Management’s response: The College agrees with this finding.
Show full finding ▾Hide full finding ▴Condition: It was noted during the audit that the amount of Pell awards granted to students was not accurately reported on the College’s annual Fiscal Operations Report and Application to Participate (FISAP). Criteria: Non-federal entities are required to submit the FISAP electronically, on an annual basis, for its campus-based programs to report expenditures in the previous award year. Cause: The Chief Financial Officer reported the incorrect amount of Pell awards disbursed to students. Effect: Inaccurate report was filed. Questioned costs: Not applicable. Views of Responsible Officials and Planned Corrective Actions: The College should establish a procedure that requires a separate review of the FISAP prior to submission. Management’s response: The College agrees with this finding.
Administration adjusted job responsibilities of current staff and made process changes to work with third party financial aid servicer to validate federal awards prior to submission
For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
Show full finding ▾Hide full finding ▴Condition: For one student out of four tested, there was no refund calculated which resulted in an underpayment to the student of Federal Funds earned by the student of $711. 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. Cause: The financial aid administrator was not notified that the student withdrew from the College. Effect: Earned and unearned portions of the federal award were not properly disbursed or returned. Questioned costs: The total net amount of Federal awards to students tested was $24,871 which resulted in a $3,248 error. The total amount of Federal awards disbursed to students for which an R2T4 was required to be completed was $85,860 resulting in a questioned cost of $11,213. Views of Responsible Officials and Planned Corrective Actions: The College should implement stronger controls to ensure communication to the financial aid administrator is made so that return of Title IV funding calculations are computed. Management’s response: The College agrees with this finding.
College will put controls in place between Registrar and Financial Aid to ensure enrollment status of students
2021-007
FAC accepted this audit on February 28, 2023 — management decision was due August 28, 2023.
Documentation that the required monthly School Account Statement (SAS) reconciliations were completed was only available for one out of three months tested for fiscal year 2021. This sample was not statistically valid.Cause: The College did not perform the required SAS reconciliations monthly as required.Effect: Not performing the SAS reconciliations could result in variances between the College?s records and the U.S. Department of Education?s records, which could impact the student.Questioned Costs: There were no questioned costs for this finding.Recommendation: The College should review and revise its controls over compliance to ensure that SAS reconciliations are performed monthly.Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Program - Student Financial Assistance Cluster - Federal Direct Loan ProgramFederal Agency - U.S. Department of EducationPass-Through Entity - Not applicableAssistance Listing Number - 84.268Federal Award Year - May 31, 2021Criteria: 34 CFR 668.162(b)(5) states that on a monthly basis the College must reconcile institutional records with direct loan fund records received from the Secretary and direct loan disbursement records submitted to and accepted by the Secretary.Condition: Documentation that the required monthly School Account Statement (SAS) reconciliations were completed was only available for one out of three months tested for fiscal year 2021. This sample was not statistically valid.Cause: The College did not perform the required SAS reconciliations monthly as required.Effect: Not performing the SAS reconciliations could result in variances between the College?s records and the U.S. Department of Education?s records, which could impact the student.Questioned Costs: There were no questioned costs for this finding.Recommendation: The College should review and revise its controls over compliance to ensure that SAS reconciliations are performed monthly.Views of Responsible Official(s): Management agrees with this finding.
Criteria: 34 CFR 668.162(b)(5) states that on a monthly basis the College must reconcile institutional records with direct loan fund records received from the Secretary and direct loan disbursement records submitted to and accepted by the Secretary.Action Taken: College outsourced compliance of federal student financial aid to third party. Internal control and processes have been updated subsequent to the transition.Contact: Stuart Renda, Vice President Finance & AdministrationAnticipated completion date: May 31, 2022
The change in status for four of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a roster file within 60 days. The sample was not statistically valid.Cause: Roster files were not updated in a timely mannerEffect: 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 enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate.Questioned Costs: There were no questioned costs for this finding.Recommendation: The College should review and revise its controls over compliance to ensure that student status changes are reported in a timely manner.Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Program - Student Financial Assistance Cluster - Federal Direct Loan ProgramFederal Agency - U.S. Department of EducationPass-Through Entity - Not applicableAssistance Listing Number - 84.268Federal Award Year - May 31, 2021Criteria: Title IV regulations 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. In addition, the Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of controls overapplicable compliance requirements.Condition: The change in status for four of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a roster file within 60 days. The sample was not statistically valid.Cause: Roster files were not updated in a timely mannerEffect: 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 enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate.Questioned Costs: There were no questioned costs for this finding.Recommendation: The College should review and revise its controls over compliance to ensure that student status changes are reported in a timely manner.Views of Responsible Official(s): Management agrees with this finding.
Criteria: Title IV regulations 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. In addition, the Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of controls over applicable compliance requirements.Action Taken: College outsourced compliance of federal student financial aid to third party. Internal control and processes have been updated subsequent to the transition.Contact: Stuart Renda, Vice President Finance & AdministrationAnticipated completion date: May 31, 2022
The College did not post the information required in relation to the student aid portion under HEERF I to the College?s website within the required timeframes. The College?s posting for HEERF I student aid due by October 10, 2020 was accurate of all information with the exception of reporting the information as September 18, 2020 and not the calendar quarter end of September 30, 2020. All HEERF I student aid portion funds were spent as of September 18, 2020. The College did not reportcorrectly the calendar quarters subsequent to September 30, 2020 as required by HEERF I student aid requirements.Cause: The College failed to follow reporting requirements for HEERF.Effect: The College did not provide the public with accurate and reliable data regarding its use of HEERF I funds.Questioned Costs: There were no questioned costs for this finding.Recommendation: The College should immediately correct the reporting for HEERF I student aid on its website, as well as any reporting for HEERF II and HEERF III to be in compliance with the requirements. The College should also review its processes and procedures to ensure that proper reporting is occurring timely.Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Program - Education Stabilization Fund - Higher Education Emergency Relief Fund - Student Aid PortionFederal Agency - U.S. Department of EducationPass-Through Entity - Not applicableAssistance Listing Number - 84.425EFederal Award Year - May 31, 2021Criteria: Beginning on May 6, 2020, the U.S. Department of Education (ED) required institutions that received funding through the Higher Education Emergency Relief Fund (HEERF) through the Coronavirus Aid, Relief, and Economic Security Act (CARES) (HEERF I) Section 18004(a)(1) Student Aid Portion Award to publicly post certain information on their website no later than 30 days after receipt of the award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED decreased the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) (HEERF II) and American Rescue Plan (ARP) (HEERF III), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the "final report" box. Institutions must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021.Condition: The College did not post the information required in relation to the student aid portion under HEERF I to the College?s website within the required timeframes. The College?s posting for HEERF I student aid due by October 10, 2020 was accurate of all information with the exception of reporting the information as September 18, 2020 and not the calendar quarter end of September 30, 2020. All HEERF I student aid portion funds were spent as of September 18, 2020. The College did not reportcorrectly the calendar quarters subsequent to September 30, 2020 as required by HEERF I student aid requirements.Cause: The College failed to follow reporting requirements for HEERF.Effect: The College did not provide the public with accurate and reliable data regarding its use of HEERF I funds.Questioned Costs: There were no questioned costs for this finding.Recommendation: The College should immediately correct the reporting for HEERF I student aid on its website, as well as any reporting for HEERF II and HEERF III to be in compliance with the requirements. The College should also review its processes and procedures to ensure that proper reporting is occurring timely.Views of Responsible Official(s): Management agrees with this finding.
Criteria: Beginning on May 6, 2020, the U.S. Department of Education (ED) required institutions that received funding through the Higher Education Emergency Relief Fund (HEERF) through the Coronavirus Aid, Relief, and Economic Security Act (CARES) (HEERF I) Section 18004(a)(1) Student Aid Portion Award to publicly post certain information on their website no later than 30 days after receipt of the award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED decreased the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) (HEERF II) and American Rescue Plan (ARP) (HEERF III), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the "final report" box. Institutions must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021.Action Taken: Administration will review federal requirements to ensure timely reporting is complete for the CARES and HEERF funds.Contact: Stuart Renda, Vice President Finance & AdministrationAnticipated completion date: May 31, 2022
During the year, the College disbursed Federal Work Study (FWS) funds and Federal Supplementary Educational Opportunity Grant (SEOG) funds of $51,599 and $107,922, respectively, but drew down $63,722 and $129,680 of FWS and SEOG respectively. Accordingly, the College overdrew FWS and SEOG by $12,123 and $21,758, respectively, and did not follow correct procedures under HCM1. HCM1 is a more stringent payment method required by the DOE when an institution is determined to be of higher risk financially. Institutions under HCM1 should only draw down funds after applying awards to student accounts. No funds should be drawn down in advance of applying the funds to the student accounts.Cause: The College did not follow correct procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method.Effect: The College did not disburse federal funds before drawing down funds as required by the HCM1 payment method.Questioned Costs: The total amount of federal funds overdrawn was $33,881.Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are in compliance with the HCM1 payment method.Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Program - Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants and Federal Work-Study ProgramFederal Agency - U.S. Department of EducationPass-Through Entity - Not applicableAssistance Listing Number - 84.007 and 84.033Federal Award Year - May 31, 2021Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education (DOE).Condition: During the year, the College disbursed Federal Work Study (FWS) funds and Federal Supplementary Educational Opportunity Grant (SEOG) funds of $51,599 and $107,922, respectively, but drew down $63,722 and $129,680 of FWS and SEOG respectively. Accordingly, the College overdrew FWS and SEOG by $12,123 and $21,758, respectively, and did not follow correct procedures under HCM1. HCM1 is a more stringent payment method required by the DOE when an institution is determined to be of higher risk financially. Institutions under HCM1 should only draw down funds after applying awards to student accounts. No funds should be drawn down in advance of applying the funds to the student accounts.Cause: The College did not follow correct procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method.Effect: The College did not disburse federal funds before drawing down funds as required by the HCM1 payment method.Questioned Costs: The total amount of federal funds overdrawn was $33,881.Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are in compliance with the HCM1 payment method.Views of Responsible Official(s): Management agrees with this finding.
Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.162(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements from the U.S. Department of Education (DOE).Action Taken: College outsourced compliance of federal student financial aid to third party. Internal control and processes have been updated subsequent to the transition.Contact: Stuart Renda, Vice President Finance & AdministrationAnticipated completion date: May 31, 2022
2020-002
For two students out of seven selected for testing, the amount of the Title IV refund was calculated incorrectly, resulting with one student receiving an underpayment of Federal Direct Loans of $127 and the other receiving an overpayment of Federal Direct Loans of $944. Additionally, for student receiving the underpayment, the return of the unearned portion of Title IV funds calculation was not performed within 45 days after the date the College determined the student dropped below half-timestatus. Our sample was not statistically valid.Cause: The College did not apply the correct end date for the semester when performing calculations and the College did not complete all calculations timely.Effect: The College refunded erroneous amounts of Federal Direct Loans for two students selected for testing, resulting in overpayment and underpayment of students and did not refund amounts timely.Questioned Costs: The total net amount of Federal Direct Loans overpayment for students tested was $817. The total amount of Federal Direct Loans disbursed in our sample was $56,451 in the population of students who dropped below half-time status was $141,395. This results in a projected questioned cost of $2,047.Recommendation: The College should implement a thorough review process of calculations to ensure the proper dates are being used and add a policy to ensure timely completion of any return of Title IV calculations.Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Program - Student Financial Assistance Cluster, Federal Direct Student Loans, Federal Pell Grant Program, Federal Perkins Loans Program, Federal Supplemental Educational Opportunity Grants and Federal Work-Study ProgramFederal Agency - U.S. Department of EducationPass-Through Entity - Not applicableAssistance Listing Number ? 84.268, 84.063, 84.038, 84.007 and 84.033Federal Award Year - May 31, 2021Criteria: 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 laterthan 45 days after the withdrawal date.Condition: For two students out of seven selected for testing, the amount of the Title IV refund was calculated incorrectly, resulting with one student receiving an underpayment of Federal Direct Loans of $127 and the other receiving an overpayment of Federal Direct Loans of $944. Additionally, for student receiving the underpayment, the return of the unearned portion of Title IV funds calculation was not performed within 45 days after the date the College determined the student dropped below half-timestatus. Our sample was not statistically valid.Cause: The College did not apply the correct end date for the semester when performing calculations and the College did not complete all calculations timely.Effect: The College refunded erroneous amounts of Federal Direct Loans for two students selected for testing, resulting in overpayment and underpayment of students and did not refund amounts timely.Questioned Costs: The total net amount of Federal Direct Loans overpayment for students tested was $817. The total amount of Federal Direct Loans disbursed in our sample was $56,451 in the population of students who dropped below half-time status was $141,395. This results in a projected questioned cost of $2,047.Recommendation: The College should implement a thorough review process of calculations to ensure the proper dates are being used and add a policy to ensure timely completion of any return of Title IV calculations.Views of Responsible Official(s): Management agrees with this finding.
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.Action Taken: College outsourced compliance of federal student financial aid to third party. Internal control and processes have been updated subsequent to the transition.Contact: Stuart Renda, Vice President Finance & AdministrationAnticipated completion date: May 31, 2022
FAC accepted this audit on August 29, 2021 — management decision was due March 1, 2022.
The College requested the total 2019-2020 Federal Work-Study Program authorized amount of $75,796 on November 7, 2019 and the total 2019-2020 Federal Supplemental Educational Opportunity Grant authorized amount of $123,626 on May 10, 2019 from the DOE, before disbursements under these programs were made to eligible parents and students. Cause: The College did not follow correct procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College did not disburse federal funds before drawing down funds as required by the HCM1 payment method. Questioned Costs: The total amount of federal funds not disbursed timely amounted to $199,422. Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are in compliance with the HCM1 payment method. Views of Responsible Official(s): Management agrees with this finding
Show full finding ▾Hide full finding ▴Finding 2020-002: Cash Management (Repeat Finding) ? Significant Deficiency Federal Program - Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants and Federal Work-Study Program Federal Agency - U.S. Department of Education Pass-Through Entity - Not applicable CFDA Number - 84.007 and 84.033 Federal Award Year - May 31, 2020 Criteria: Under the Heightened Cash Monitoring 1 (HCM1) payment method as stated in 34 CFR 668.12(d), the College must first make distributions to eligible students and parents and pay any remaining credit balances before request or receipt of funds for the amount of those disbursements- from the U.S. Department of Education (DOE). Condition: The College requested the total 2019-2020 Federal Work-Study Program authorized amount of $75,796 on November 7, 2019 and the total 2019-2020 Federal Supplemental Educational Opportunity Grant authorized amount of $123,626 on May 10, 2019 from the DOE, before disbursements under these programs were made to eligible parents and students. Cause: The College did not follow correct procedures for requesting federal funds and disbursing them to student accounts timely as required by the HCM1 payment method. Effect: The College did not disburse federal funds before drawing down funds as required by the HCM1 payment method. Questioned Costs: The total amount of federal funds not disbursed timely amounted to $199,422. Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are in compliance with the HCM1 payment method. Views of Responsible Official(s): Management agrees with this finding
FINDING 2020-002 Finding 2020-002: Cash Management (Repeat Finding) ? Significant Deficiency Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are in compliance with the HCM1 payment method. Action Taken: To meet the changes landscape, the College will outsource compliance function to professionals at Financial Aid Services. Contact person: Stuart Renda, Vice President of Finance and Administration Anticipated completion date: January 30, 2021
2019-003
Part III, Part IV and Part V of the College's FISAP for the award year July 1, 2018 through June 30, 2019, which is required to be filed during the period of July 1, 2019 to June 30, 2020, do not reconcile to the activity in the College's records for the Federal Perkins Loan, Supplemental Education Opportunity Grant, and Federal Work-Study Programs. Cause: The FISAP was not reconciled and reviewed prior to filing. Effect: The FISAP was submitted with information that did not reconcile to the activity in the College's programs. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: The College should review its procedures relating to the filing of the FISAP. Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Finding 2020-003: Reporting - Special Reporting (Repeat Finding) ? Significant Deficiency Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not applicable CFDA Number - 84.007; 84.033; 84.038; 84.063; 84.268 Federal Award Year - May 31, 2020 Criteria: DOE Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) is required to be submitted annually to receive funds for campus-based programs. Condition: Part III, Part IV and Part V of the College's FISAP for the award year July 1, 2018 through June 30, 2019, which is required to be filed during the period of July 1, 2019 to June 30, 2020, do not reconcile to the activity in the College's records for the Federal Perkins Loan, Supplemental Education Opportunity Grant, and Federal Work-Study Programs. Cause: The FISAP was not reconciled and reviewed prior to filing. Effect: The FISAP was submitted with information that did not reconcile to the activity in the College's programs. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: The College should review its procedures relating to the filing of the FISAP. Views of Responsible Official(s): Management agrees with this finding.
FINDING 2020-003: Reporting - Special Reporting (Repeat Finding) ? Significant Deficiency Recommendation: The College should review its procedures relating to the filing of the FISAP Action Taken: College has worked with department official to reconcile the beginning balances and develop a new reporting with external professionals at Financial Aid Services Contact person: Stuart Renda, Vice President of Finance and Administration Anticipated completion date: June 30, 2021
2019-004
The College has not performed a risk assessment as required by 16 CFR 314.1(b). Cause: The College did not perform the risk assessment as required. Effect: Failure to comply with the requirements of 16 CFR 314.1(b) puts the College at risk of compromising consumer nonpublic personal information. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: The College should perform and document an annual risk assessment to determine the College's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the College should have at least one risk statement aligned or referenced to each of the three required areas noted at 16 CFR 314.4 (b). The College should also identify and document at least one safeguard (i.e., control) for each of the risks identified and documented in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Views of Responsible Official(s): Management agrees with this finding.
Show full finding ▾Hide full finding ▴Finding 2020-004: Special Tests - Gramm-Leach Bliley Act Compliance Federal Program - Student Financial Assistance Cluster Federal Agency - U.S. Department of Education Pass-Through Entity - Not applicable CFDA Number - 84.007; 84.033; 84.038; 84.063; 84.268 Federal Award Year - May 31, 2020 Criteria: Title IV regulation 16 CFR 314.1(b) requires Institutions to protect student financial aid information by designating an individual to coordinate the information security program; perform a risk assessment that addresses (1) employee training and management, (2) information transmission and disposal, and (3) detecting, preventing and responding to attacks, intrusions, or other system failures; and document safeguards for risks identified. Condition: The College has not performed a risk assessment as required by 16 CFR 314.1(b). Cause: The College did not perform the risk assessment as required. Effect: Failure to comply with the requirements of 16 CFR 314.1(b) puts the College at risk of compromising consumer nonpublic personal information. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: The College should perform and document an annual risk assessment to determine the College's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the College should have at least one risk statement aligned or referenced to each of the three required areas noted at 16 CFR 314.4 (b). The College should also identify and document at least one safeguard (i.e., control) for each of the risks identified and documented in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Views of Responsible Official(s): Management agrees with this finding.
FINDING 2020-004: Special Tests ? Gramm-Leach Bliley Act Compliance Recommendation: The College should perform and document an annual risk assessment to determine the College?s specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the College should have at least one risk statement aligned or referenced to each of the three required areas noted at 16 CFR 314.4 (b). The College should also identify and document at least one safeguard (i.e., control) for each of the risks identified and documented in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: College will implement a plan to evaluate the risk controls in the current system with a risk assessment. Contact person: Charles Prothero, Chief Information Technology Officer Anticipated completion date: October 1, 2021
FAC accepted this audit on May 11, 2020 — management decision was due November 11, 2020.
FINDING 2019-002 - CFDA 84.007 ? Matching CRITERIA:The Federal Work Study Program and the Federal Supplemental Educational Opportunity Grant Program have non-Federal share matching requirements. Unless a waiver has been obtained from the U.S. Department of Education, the Federal share of awards may not exceed 75 percent of the total program awards made by the College. (34 CFR 676.21 and 34 CFR 675.26). CONDITION: Keystone College did not receive a waiver for the fiscal year ended May 31, 2019 and did not match the Federal share of awards for the Supplemental Educational Opportunity Grant Program. CONTEXT: Keystone College did not match the Federal share of award for the program. CAUSE: The Director of Financial Aid did not correctly calculate the required match for the College. EFFECT: Keystone College did not match the Federal share of awards for the program. QUESTIONED COSTS: There were none. RECOMMENDATION: Keystone College should review its procedures relating to the application for the waiver of the non-Federal matching requirement and the calculation of the required College match.
Show full finding ▾Hide full finding ▴FINDING 2019-002 - CFDA 84.007 ? Matching CRITERIA:The Federal Work Study Program and the Federal Supplemental Educational Opportunity Grant Program have non-Federal share matching requirements. Unless a waiver has been obtained from the U.S. Department of Education, the Federal share of awards may not exceed 75 percent of the total program awards made by the College. (34 CFR 676.21 and 34 CFR 675.26). CONDITION: Keystone College did not receive a waiver for the fiscal year ended May 31, 2019 and did not match the Federal share of awards for the Supplemental Educational Opportunity Grant Program. CONTEXT: Keystone College did not match the Federal share of award for the program. CAUSE: The Director of Financial Aid did not correctly calculate the required match for the College. EFFECT: Keystone College did not match the Federal share of awards for the program. QUESTIONED COSTS: There were none. RECOMMENDATION: Keystone College should review its procedures relating to the application for the waiver of the non-Federal matching requirement and the calculation of the required College match.
FINDING 2019-002 Federal Award Findings and Question Costs: CFDA84.007 - Matching Recommendation: Keystone College should review its procedures relating to the application for the waiver of the non- Federal matching requirement and the calculation of the required College match. Action Taken: The College will continue to review procedures and make necessary changes needed for calculating the required College match. Contact person: Delaina Jayne, Assistant VP of Student Central & Director of Financial Aid Anticipated completion date: May 31, 2020
FINDING 2019-003 - CFDA 84.007 and 84.033 - Cash Management CRITERIA: Under the Heightened Cash Monitoring (HCM) payment method as stated in 34 CFR 668.162(d), the Institution must first make disbursements to eligible students and parents and pay any remaining credit balances before it requests or receives funds for the amount of those disbursements from the U.S. Department of Education. CONDITION: Keystone College requested the total 2018-2019 Federal Work-Study Program authorization in the amount of $85,638 on July 25, 2018. The first disbursement to students was the September 7, 2018 payroll and the last disbursement was the May 31, 2019 payroll. The total amount of Federal Work Study funds disbursed amounted to $78,701. The College requested the total 2019-2020 Federal Supplemental Educational Opportunity Grants authorization in the amount of $123,626 on May 10, 2019. CONTEXT: Federal funds were not drawn down as required by the HCM payment method. CAUSE: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely. EFFECT: The College did not disburse federal funds drawn down as required by the HCM payment method. QUESTIONED COSTS: The total amount of federal funds not disbursed timely amounted to $209,264 RECOMMENDATION: Keystone College should review its procedures relating to the requesting and disbursement of federal funds to ensure they are in compliance with the HCM payment method.
Show full finding ▾Hide full finding ▴FINDING 2019-003 - CFDA 84.007 and 84.033 - Cash Management CRITERIA: Under the Heightened Cash Monitoring (HCM) payment method as stated in 34 CFR 668.162(d), the Institution must first make disbursements to eligible students and parents and pay any remaining credit balances before it requests or receives funds for the amount of those disbursements from the U.S. Department of Education. CONDITION: Keystone College requested the total 2018-2019 Federal Work-Study Program authorization in the amount of $85,638 on July 25, 2018. The first disbursement to students was the September 7, 2018 payroll and the last disbursement was the May 31, 2019 payroll. The total amount of Federal Work Study funds disbursed amounted to $78,701. The College requested the total 2019-2020 Federal Supplemental Educational Opportunity Grants authorization in the amount of $123,626 on May 10, 2019. CONTEXT: Federal funds were not drawn down as required by the HCM payment method. CAUSE: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely. EFFECT: The College did not disburse federal funds drawn down as required by the HCM payment method. QUESTIONED COSTS: The total amount of federal funds not disbursed timely amounted to $209,264 RECOMMENDATION: Keystone College should review its procedures relating to the requesting and disbursement of federal funds to ensure they are in compliance with the HCM payment method.
FINDING 2019-003 Federal Award Findings and Question Costs: CFDA 84.007 and 84.033 - Cash Management Recommendation: Keystone College should review its procedures relating to the requesting and disbursement of federal funds to ensure they are in compliance with the HCM payment method. Action Taken: The College will ensure compliance with HCM payments by creating and implementing new procedures between the Finance and Financial Aid departments. Contact person: Stuart Renda, Vice President of Finance and Administration Anticipated completion date: May 31, 2020
FINDING 2019-004 - Reporting - Special Reporting CRITERIA: ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) - This electronic report is submitted annually to receive funds for the campus-based programs. The school uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. CONDITION: Part III, Part IV and Part V of Keystone College?s FISAP for the award year July 1, 2018 through June 30, 2019 do not reconcile to the activity in the College?s Federal Perkins Loan, Supplemental Educational Opportunity Grant and Work-Study Programs. CONTEXT: The FISAP was not reconciled to the activity in the College?s programs. CAUSE: The FISAP was not reconciled and reviewed prior to filing. EFFECT: The FISAP was submitted with information that did not reconcile to the activity in the College?s programs. QUESTIONED COSTS: There were none. RECOMMENDATION: Keystone College should review its procedures relating to the filing of the FISAP.
Show full finding ▾Hide full finding ▴FINDING 2019-004 - Reporting - Special Reporting CRITERIA: ED Form 646-1, Fiscal Operations Report and Application to Participate (FISAP) (OMB No. 1845-0030) - This electronic report is submitted annually to receive funds for the campus-based programs. The school uses the Fiscal Operations Report portion to report its expenditures in the previous award year and the Application to Participate portion to apply for the following year. CONDITION: Part III, Part IV and Part V of Keystone College?s FISAP for the award year July 1, 2018 through June 30, 2019 do not reconcile to the activity in the College?s Federal Perkins Loan, Supplemental Educational Opportunity Grant and Work-Study Programs. CONTEXT: The FISAP was not reconciled to the activity in the College?s programs. CAUSE: The FISAP was not reconciled and reviewed prior to filing. EFFECT: The FISAP was submitted with information that did not reconcile to the activity in the College?s programs. QUESTIONED COSTS: There were none. RECOMMENDATION: Keystone College should review its procedures relating to the filing of the FISAP.
FINDING 2019-004 Reporting - Special Reporting Recommendation: Keystone College should review its procedures relating to the filing of the FISAP. Action Taken: The College is in the process of restructuring the Financial Aid and Student Central departments to ensure compliance with all future filings. Contact person: Stuart Renda, Vice President of Finance and Administration Anticipated completion date: May 31, 2020
FAC accepted this audit on April 24, 2019 — management decision was due October 24, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
FAC accepted this audit on December 6, 2017 — management decision was due June 6, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on February 23, 2017 — management decision was due August 23, 2017.
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