EIN: 251186257
UEI: D44KX37DNUS9
Audited by: McClintock & Associates, PC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 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 (5 days ago).
What is a management decision? →FAC accepted this audit on November 14, 2024 — management decision was due May 14, 2025.
FINDING 2024-001: PELL GRANT AWARD Condition In eight of the thirty-six student files tested for compliance with Federal Pell Grant Program requirements, we determined the Institution miscalculated the student’s Pell award in one or more payment periods. The students involved were #’s 29, 33, 38, 41, 42, 46, 54 and 60. Criteria For the 2023/2024 award year, Pell Grant awards are based on a student’s Expected Family Contribution (EFC), the academic year structure of the student’s educational program, and the cost of attendance (COA) for a full-time student for a full academic year. The Scheduled Award amounts are specified on the Pell Grant payment schedules released by the U.S. Department of Education each year. For term-based programs, awards are also based on a student’s enrollment status. If the student does not begin attendance in all classes for a payment period, resulting in a change in the student’s enrollment status, a school must recalculate the student’s award for that payment period based on the lower enrollment status. Cause The students were enrolled in term-based programs offered in modules. They did not attend the same number of credits that they were originally scheduled to attend (and on which their Pell payments were based). The Institution neglected to recalculate the Pell awards and make adjustments to the student accounts. Effect and Questioned Costs As outlined below, the students were not paid the proper amount of Pell. Subsequent to our testing, the Institution returned all over awards to the Pell Grant program and offset the refunds with Institutional credits. It also provided Institutional credits (in lieu of Pell funds) to the students who were under-awarded. We verified that any resulting credit balances were sent to the students. Over (Under) Student # Disbursed Eligible Award Award Year 29 $ 2,773 $ 3,698 $ (925) 2023/2024 33 $ 392 $ 523 $ (131) 2023/2024 38 $ 2,773 $ 925 $ 1,848 2023/2024 41 $ 2,773 $ 1,849 $ 924 2023/2024 42 $ 2,454 $ 818 $ 1,636 2022/2023 46 $ 805 $ 536 $ 269 2023/2024 54 $ 1,849 $ 925 $ 924 2023/2024 60 $ 505 $ 0 $ 505 2023/2024 Total Questioned Costs: $7,162 The Institution made seventy-three separate disbursements of Pell to the students in our sample during the fiscal year, for a total of $156,034. The errors noted above represent 11% of the disbursements that were processed, but less than 5% of the dollars that were awarded during the fiscal year. FINDING 2024-001: PELL GRANT AWARD (CONTINUED) Recommendation The Institution should implement procedures to ensure that, in the future, Pell Grant awards are awarded in accordance with the federal regulations. Views of Responsible Officials The Institution concurs with this finding.
Show full finding ▾Hide full finding ▴FINDING 2024-001: PELL GRANT AWARD Condition In eight of the thirty-six student files tested for compliance with Federal Pell Grant Program requirements, we determined the Institution miscalculated the student’s Pell award in one or more payment periods. The students involved were #’s 29, 33, 38, 41, 42, 46, 54 and 60. Criteria For the 2023/2024 award year, Pell Grant awards are based on a student’s Expected Family Contribution (EFC), the academic year structure of the student’s educational program, and the cost of attendance (COA) for a full-time student for a full academic year. The Scheduled Award amounts are specified on the Pell Grant payment schedules released by the U.S. Department of Education each year. For term-based programs, awards are also based on a student’s enrollment status. If the student does not begin attendance in all classes for a payment period, resulting in a change in the student’s enrollment status, a school must recalculate the student’s award for that payment period based on the lower enrollment status. Cause The students were enrolled in term-based programs offered in modules. They did not attend the same number of credits that they were originally scheduled to attend (and on which their Pell payments were based). The Institution neglected to recalculate the Pell awards and make adjustments to the student accounts. Effect and Questioned Costs As outlined below, the students were not paid the proper amount of Pell. Subsequent to our testing, the Institution returned all over awards to the Pell Grant program and offset the refunds with Institutional credits. It also provided Institutional credits (in lieu of Pell funds) to the students who were under-awarded. We verified that any resulting credit balances were sent to the students. Over (Under) Student # Disbursed Eligible Award Award Year 29 $ 2,773 $ 3,698 $ (925) 2023/2024 33 $ 392 $ 523 $ (131) 2023/2024 38 $ 2,773 $ 925 $ 1,848 2023/2024 41 $ 2,773 $ 1,849 $ 924 2023/2024 42 $ 2,454 $ 818 $ 1,636 2022/2023 46 $ 805 $ 536 $ 269 2023/2024 54 $ 1,849 $ 925 $ 924 2023/2024 60 $ 505 $ 0 $ 505 2023/2024 Total Questioned Costs: $7,162 The Institution made seventy-three separate disbursements of Pell to the students in our sample during the fiscal year, for a total of $156,034. The errors noted above represent 11% of the disbursements that were processed, but less than 5% of the dollars that were awarded during the fiscal year. FINDING 2024-001: PELL GRANT AWARD (CONTINUED) Recommendation The Institution should implement procedures to ensure that, in the future, Pell Grant awards are awarded in accordance with the federal regulations. Views of Responsible Officials The Institution concurs with this finding.
Pittsburgh Institute of Mortuary Science Student Financial Aid Audit Corrective Action Plan This corrective action plan is in response to the institute's single audit report for the year ended June 30, 2024, prepared by McClintock & Associates, P.C. Finding 2024-001: Pell Grant Award Recommendation: The Institution should adjust the 2023-2024 Pell awards according to the amounts listed in Summary. Corrective Action: The Institute has returned the Pell awards in the amounts listed in the Summary. The Institute wrote off the dollar amounts so as not to penalize the students identified. The Institute has also reviewed all students who received a Pell award du1ing the current Fiscal Year and recalculated and returned funds appropriately. The Institute again wrote off these dollar amounts. The Institute now has a clear understanding as to how and when the Pell awards should be recalculated. Since this item directly applies to our online student population only, the Institute has rewritten and implemented a specific "Pell Recalculation for Online Students" portion into the already robust Withdrawal procedure. Additionally, the Institute has initiated a weekly meeting to review all students who changed statuses during the prior week. Any online, Pell-eligible students will be recalculated during the meeting and funds will be returned within 7 days of the meeting when deemed necessary. Persons Responsible for Corrective Action: Financial Aid Advisor, Senior Financial Aid Administrator, and Registrar/Director of Administrative & Student Services. Anticipated Completion Date for Corrective Action: The Corrective Action was immediately implemented in response to the auditors' recommendation.
2023-001
FAC accepted this audit on March 18, 2024 — management decision was due September 18, 2024.
We tested thirty-seven files, twenty-one of which were Pell Grant recipients, and one student received a Pell grant in excess of her allowed amount and one student did not receive the full amount of her allowed Pell grant. The students were eligible for $5,784, but received $6,164. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2022-001. Cause: The condition was caused by using an incorrect number of credits while calculating the Pell. Effect: The result is the student received ineligible Pell monies. Question Costs: $811 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $811 to the Department of Education, credit $431 to the student's account and increase controls over Pell Grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2023-001: INCORRECT PELL GRANTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN: 84.063 FEDERAL AWARD YEAR: 2022-2023 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student’s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, twenty-one of which were Pell Grant recipients, and one student received a Pell grant in excess of her allowed amount and one student did not receive the full amount of her allowed Pell grant. The students were eligible for $5,784, but received $6,164. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2022-001. Cause: The condition was caused by using an incorrect number of credits while calculating the Pell. Effect: The result is the student received ineligible Pell monies. Question Costs: $811 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $811 to the Department of Education, credit $431 to the student's account and increase controls over Pell Grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2023-001: INCORRECT PELL GRANTS A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT A1 RECEIVED THE INCORRECT AMOUNT OF PELL AND STUDENT B1 WAS INCORRECTLY ADJUSTED DURING THE R2T4 PROCESS. B. ACTIONS TAKEN OR PLANNED: PIMS HAS FOUND THAT AN EXTRA LAYER OF REVIEW ON EACH PELL DISBURSEMENT ROSTER FROM FAME WILL ELIMINATE INCORRECT PAYMENTS. PIMS REPORTS THE NUMBER OF CREDITS AND ENROLLMENT STATUS TO FAME THEN FAME REQUESTS THE FUNDS BASED ON THIS INFORMATION THAT PIMS ELECTRONICALLY TRANSMITS. IN MOST CASES THE PAYMENT AND THE ENROLLMENT STATUS MATCH BUT FOR STUDENT A1 THAT IS NOT THE CASE. GOING FORWARD, AT THE TIME THE ROSTER IS PRODUCED THE FA OFFICE WILL VERIFY EACH PAYMENT BEFORE THE ROSTER GOES TO THE BUSINESS OFFICE. PIMS WILL ALSO RETURN THE $811 OF 21/22 PELL THAT STUDENT A1 WAS INELLIGIBLE FOR. PELL ADJUSTMENTS DURING THE R2T4 PROCESS WILL BE LOOKED AT BY BOTH THE FA PROCESSOR AND SUPERVISOR. AS WITH THE PELL MATCHING THE STUDENTS' ENROLLMENT WHILE ATTENDING THE INSTITUTE'S FA OFFICE UNDERSTANDS THAT THE SAME CONCEPT IS APPLIED WHEN A STUDENT WITHDRAWAL AND A PELL RE-CALCULATION IS REQUIRED. PIMS WILL RE-REQUEST ON BEHALF OF STUDENT B1 $431 IN PELL GRANT FUNDS.
2022-001
We tested thirty-seven files, thirty-four of which were Federal Direct Loan recipients, and one student was overawarded a Federal Direct subsidized loan. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by using an incorrect number of credits while calculating the subsidized. Effect: The result is the student received ineligible loan proceeds. Question Costs: $2,709 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $2,709 to the Department of Education and increase controls over Direct Loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2023-002: OVERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN: 84.268 FEDERAL AWARD YEAR: 2022-2023 Compliance Requirement: Eligibility (E.) Criteria: A third year student can receive up to $5,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested thirty-seven files, thirty-four of which were Federal Direct Loan recipients, and one student was overawarded a Federal Direct subsidized loan. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by using an incorrect number of credits while calculating the subsidized. Effect: The result is the student received ineligible loan proceeds. Question Costs: $2,709 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $2,709 to the Department of Education and increase controls over Direct Loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2023-002: OVERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B2 WAS NOT PROPERLY PRORATED WHEN FEDERAL DIRECT LOANS WERE CALCULATED. B. ACTIONS TAKEN OR PLANNED: MOSTLY ALL STUDENTS THAT ATTEND PIMS NEED TO BE PRORATED FOR THEIR LAST ACADEMIC YEAR. THIS STUDENT SHOULD HAVE BEEN PRORATED, PIMS WILL RETURN THE $2,709 THE STUDENT IS INELIGIBLE FOR. FA MANAGEMENT HAS BEGUN CONDUCTING QUARTERLY FILE REVIEWS WHERE END PROCESSING AND STUDENT PRORATION CALCULATIONS CAN CONTINUE TO BE MONITORED FOR COMPLIANCE.
We tested thirteen drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2022-003. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $1,478 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2023-003: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN: 84.268 FEDERAL AWARD YEAR: 2022-2023 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student’s withdrawal (34 CFR 668.22, 685.306). Condition: We tested thirteen drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2022-003. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $1,478 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2023-003: LATE REFUND A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B1 WAS REFUNDED WITHIN THE FEDERAL GUIDELINE TIME ALLOTMENT. B. ACTIONS TAKEN OR PLANNED: THE INSTITUTE HAS IMPROVED THE WITHDRAWAL PROCESS AND PROCEDURES UNDER NEW MANAGEMENT ALONG WITH WORKING MORE CLOSELY WITH THE ENROLLMENT OFFICE TO WATCH FOR STUDENTS THAT DO NOT BEGIN A NEW TERM.
2022-003
We tested thirteen drop students and found two incorrect refund calculations. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Finding 2022-002. Cause: The condition was caused by using incorrect amounts in Step 1 of the Return to Title IV refund calculation for one student and by using incorrect charges in Step 5 of the Return to Title IV refund calculation for the other student. Effect: The result is the Institution refunded incorrect amounts to the Department of Education. Question Costs: $352 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $352 to the Department of Education and increase controls over refunds. There is no liablity for the remaining $362, as this was due to overrefunding loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2023-004: INCORRECT REFUND CALCULATIONS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN: 84.268 FEDERAL AWARD YEAR: 2022-2023 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested thirteen drop students and found two incorrect refund calculations. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Finding 2022-002. Cause: The condition was caused by using incorrect amounts in Step 1 of the Return to Title IV refund calculation for one student and by using incorrect charges in Step 5 of the Return to Title IV refund calculation for the other student. Effect: The result is the Institution refunded incorrect amounts to the Department of Education. Question Costs: $352 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $352 to the Department of Education and increase controls over refunds. There is no liablity for the remaining $362, as this was due to overrefunding loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2023-004: INCORRECT REFUND CALCULATIONS A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT B3 AND B 1 WERE INCORRECTLY REFUNDED DUE TO MISSING OR INCORRECT INFORMATION ON THE R2T4. PIMS WILL REFUND THE $352 OWED TO THE DOE. B. ACTIONS TAKEN OR PLANNED: PIMS FA OFFICE HAS MOVED TO COMPLETING THE R2T4 ONLINE TO HELP ELIMINATE CALCULATION ERRORS. ALL R2T4'S ARE THEN REVIEWED BY FA MANAGER TO ENSURE ALL FIGURES ARE ENTERED CORRECTLY AND AUTO CALCULATING CORRECTLY.
2022-002
We tested thirty-seven files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for ten students. We consider this finding to be a material weakness. Cause: The condition was caused by a breakdown in controls over enrollment reporting. Effect: The result is the students’ enrollment dates were reported to NSLDS inaccurately or were missing. Question Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution update the effective dates in NSLDS and increase controls over enrollment reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2023-005: INACCURATE ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN: 84.268 FEDERAL AWARD YEAR: 2022-2023 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: We tested thirty-seven files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for ten students. We consider this finding to be a material weakness. Cause: The condition was caused by a breakdown in controls over enrollment reporting. Effect: The result is the students’ enrollment dates were reported to NSLDS inaccurately or were missing. Question Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution update the effective dates in NSLDS and increase controls over enrollment reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
FINDING 2023-005: INACCURATE ENROLLMENT STATUS REPORTING A. COMMENTS ON FINDING AND RECOMMENDATION(S): PIMS AGREES WITH THE FINDINGS OF THE AUDITORS THAT STUDENT A AND STUDENTS LISTED AS B WERE NOT PROPERLY REPORTED. B. ACTIONS TAKEN OR PLANNED: PIMS HAS FOUND THAT UPDATES NEED TO BE VERIFIED AND MADE DIRECTLY IN NSLDS. PIMS HAS RELIED MOSTLY ON FAME OUT THIRD-PARTY SERVICER TO COMPLETE THE MAJORITY OF ENROLLMENT REPORTING, GOING FORWARD ALL REPORTING WILL BE EITHER DONE DIRECTLY TO NSLDS OR REVIEWED AFTER THE INFORMATION IS RELAYED THROUGH FAME'S ENROLLMENT REPORTING SYSTEM (SSCR)
FAC accepted this audit on November 29, 2022 — management decision was due May 29, 2023.
We tested thirty-seven files, seventeen of which were Pell Grant recipients, and two students did not receive the full amount of their allowed Pell grants. The students were eligible for $4,035 but received $2,958. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-001. Cause: The condition was caused by an overisght in the financial aid department. Effect: The result is the students did not receive $1,077 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution credit $1,077 to the students' accounts. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-001: UNDERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, seventeen of which were Pell Grant recipients, and two students did not receive the full amount of their allowed Pell grants. The students were eligible for $4,035 but received $2,958. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-001. Cause: The condition was caused by an overisght in the financial aid department. Effect: The result is the students did not receive $1,077 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution credit $1,077 to the students' accounts. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-001 ? Underawarded Pell Grants: During the audit, it was noted that two students were not awarded the full amount of their allowable Pell grants. It was recommended that the school credit the appropriate students? accounts $1,077. The Institution agrees with the finding. The school has made the appropriate corrections to the student accounts and both students have received their additional funding. The Institute recognized that our 3rd party Servicer was not disbursing the correct amount of Pell grant funds and requested that they complete a full audit of disbursements, the error on their end has been corrected and should not lead to additional findings moving forward.
2021-001
We tested twelve drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an error in Steps 1 and 5 of the Return to Title IV refund calculation. Effect: As a result, the Institution is holding funds that need to be returned to the Department. Question Costs: $1,592 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $1,592 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-002: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twelve drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an error in Steps 1 and 5 of the Return to Title IV refund calculation. Effect: As a result, the Institution is holding funds that need to be returned to the Department. Question Costs: $1,592 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $1,592 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-002 ? Incorrect Refund Calculation: During the audit, one student had an incorrect refund calculation resulting in $1,592 that should be returned to the Department of Education. The Institution agrees with the finding. The erroneous action happened due to administrative oversight, the refunds to the Department have been completed in the amount of $211.00 Pell grant and $1,381 in Subsidized Direct loan funds. The school understands the importance of calculating the Title IV refund correctly, as a new financial aid administrator and director move into these roles, more oversight from the director position will be initiated.
We tested twelve drop students in our sample and noted two late refunds. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-004. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $6,908 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-003: LATE REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 & 84.063 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twelve drop students in our sample and noted two late refunds. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2021-004. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $6,908 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-003 ? Late Refunds: During the audit, we noted two students who did not have refunds returned to the Department in a timely manner. The Institution agrees with the finding. The Institute acknowledges that the lag time between registration and financial aid did contribute to this issue. Similar to the resolution above, the director will continue to monitor these issues and work between the financial aid and business offices to ensure that refunds are made in a timely manner.
2021-004
The Institution failed to implement the required procurement policies. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-004: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement the required procurement policies. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-004 ? Insufficient Procurement Policy The Institution?s documented Procurement Policy did not contain the required elements set forth by the Department. The Institution agrees with the finding. The Institute agrees that while they thought that they were following the Department?s guidance in-regards-to the procurement of HERFF funds, they misinterpreted the information which created the findings. Now that the Institute has a better understanding of the process of HERFF procurement and disbursement, and if additional funding is available in the future, the Institute will change its procedures to match those of the Department as learned from the errors found in this audit.
The Institution failed to implement the required standards of conduct. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the standards of conduct. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-005: INSUFFICIENT STANDARD OF CONDUCT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement Suspension & Debarment (I.) Criteria: An Institution must have standards of conduct that cover conflicts of interest and govern the performance of its employees engaged in the selection, award, and administration of contracts (2 C.F.R. ?200.318(c) and 48 C.F.R. ?? 52.203-13 and 52.303-16). Condition: The Institution failed to implement the required standards of conduct. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Question Costs: $0 Recommendation: We recommend the Institution develop and implement the standards of conduct. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-005 ? Insufficient Standard of Conduct: The Institution was unable to provide an adequate Standard of Conduct policy that contained the required elements set forth by the Department. The Institution agrees with the finding. As stated above, the institution did believe at the time that they were following the Department?s guidance. The same response is true for this finding as finding 2022-004.
The Institution incorrectly reported the total amount of funds received and the total amount of quarterly expenditures on its Institutional report for the quarter ended June 30, 2022. The Institution's student quarterly report for the quarter ended March 31, 2022 is missing one of the seven required data elements set forth by the Department. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution understated the amount of total funds received and total institutional expenditures for the quarter ended June 30, 2022, and did not list the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission on its student quarterly report for the quarter ended March 31, 2022. Question Costs: $0 Recommendation: We recommend the Institution make corrections to the applicable reports. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-006: INACCURATE REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: Section 18004(e) of the CARES Act directs schools receiving funds under Section 18004 of the Act to submit a report to The Department describing the use of funds distributed from HEERF. There are three components to reporting for HEERF that are applicable to proprietary schools: 1) Quarterly public reporting on the (a)(1) Student Aid Portion; 2) Quarterly public reporting on the (a)(1) Condition: The Institution incorrectly reported the total amount of funds received and the total amount of quarterly expenditures on its Institutional report for the quarter ended June 30, 2022. The Institution's student quarterly report for the quarter ended March 31, 2022 is missing one of the seven required data elements set forth by the Department. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversight. Effect: The result is that the Institution understated the amount of total funds received and total institutional expenditures for the quarter ended June 30, 2022, and did not list the total amount of Emergency Financial Aid Grants distributed to students as of the date of submission on its student quarterly report for the quarter ended March 31, 2022. Question Costs: $0 Recommendation: We recommend the Institution make corrections to the applicable reports. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-006 ? Inaccurate Reporting: During the audit, we noted two reports that were either missing the required elements set forth by the Department, or had inaccurate information disclosed. The Institution agrees with the finding. The Institute does agree with the finding; but did believe that the reports were correct when submitted. The funds were represented on future reports. The Institute again will take this opportunity to learn from the mistakes found on this audit to ensure that the reporting issues from two of the reports will not be repeated in future reports, if any additional HERFF grants are awarded.
The Institution was late in publicly posting its Institutional Expenditure reports for the quarters ended December 31, 2021 and March 31, 2022. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is that the Department of Education and general public were not made aware of the Institution?s quarterly institutional expenditures in a timely manner. Question Costs: $0 Recommendation: We recommend the Institution increase controls over reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-007: UNTIMELY REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERFENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Reporting (L.) Criteria: As required under the CARES Act Section 18004(e) and clarified under Federal Register August 31, 2020 (85 FR 53802) and the CRRSAA Section 314(e), an Institution must publicly post the total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) as of the date of submission and updated every 45 days thereafter (subsequently changed to every quarter) and must publicly post Quarterly Budget and Expenditure Reporting forms every quarter to satisfy the Condition: The Institution was late in publicly posting its Institutional Expenditure reports for the quarters ended December 31, 2021 and March 31, 2022. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is that the Department of Education and general public were not made aware of the Institution?s quarterly institutional expenditures in a timely manner. Question Costs: $0 Recommendation: We recommend the Institution increase controls over reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-007 ? Untimely Reporting: During the audit, we noted two institutional quarterly reports that were not posted in a timely manner. The Institution agrees with the finding. The Institute agrees with the finding because we cannot procure the original webmaster records; but wants to state that the annual reports were submitted in a timely manner and that the quarterly reports were posted to our prior website for the public and the Department to view. The same response is true for this finding as finding 2022-006.
The Institution failed to disburse their ARP HEERF III student grants within 15 calendar days of the drawdown from G5. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is students were not disbursed emergency grant funds in a timely manner. The Institution drew down their ARP HEERF III student grant award on August 12, 2021 and did not disburse funds to students until March 1, 2022. Question Costs: $293,027 Recommendation: We recommend the Institution increase controls over cash management and await further guidance from the Department. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2022-008: CASH MANAGEMENT - UNTIMELY DISBURSEMENTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HIGHER EDUCATION EMERGENCY RELIEF FUNDS ALN#: 84.425E & 84.425F FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Cash Management (C.) - Student Grant Disbursements Criteria: For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department's G5 grant systems and all other ALN's should be disbursed within 3 calendar days of the drawdown from G5. Condition: The Institution failed to disburse their ARP HEERF III student grants within 15 calendar days of the drawdown from G5. We will qualify our opinion for this attribute. Cause: The condition was caused by administrative oversights. Effect: The result is students were not disbursed emergency grant funds in a timely manner. The Institution drew down their ARP HEERF III student grant award on August 12, 2021 and did not disburse funds to students until March 1, 2022. Question Costs: $293,027 Recommendation: We recommend the Institution increase controls over cash management and await further guidance from the Department. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Finding 2022-008 ? Cash Management ? Untimely Disbursements During the audit, it was noted that Student Aid Portion grant funds were not disbursed within 15 calendar days of the drawdown from G5. The Institution agrees with the finding. The Institute agrees with this finding, the funds were disbursed later than 15 days after drawdown of the funds. The school was aware that the funds were not disbursed in a timely manner due to timing issues within the department that was responsible to release the funds. In the future, the school will better prepare the checks and letters, so that the drawdown will be completed once the school is ready to release the funds.
FAC accepted this audit on November 10, 2021 — management decision was due May 10, 2022.
We tested thirty-seven files, sixteen of which were Pell Grant recipients, and one student did not receive the full amount of their allowed Pell grants. The student was eligible for $5,468 but received $2,734. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2020-001. Cause: The condition was caused by an overisght in the financial aid department. Effect: The result is the student did not receive $2,734 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: We recommend the Institution credit $2,734 to the student's account. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-001: UNDERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM ALN#: 84.063 FEDERAL AWARD YEAR: 2020-2021 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, sixteen of which were Pell Grant recipients, and one student did not receive the full amount of their allowed Pell grants. The student was eligible for $5,468 but received $2,734. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2020-001. Cause: The condition was caused by an overisght in the financial aid department. Effect: The result is the student did not receive $2,734 of eligible Pell monies. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: We recommend the Institution credit $2,734 to the student's account. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Comments on findings and recommendations - The error occurred during a timeframe that the school was converting to offering both standard and accelerated versions of our campus programs and working through how the financial aid process would work using different credit amounts for different students. This was simply an error on one student as we worked through learning the new process. The school agrees with the auditors finding. Actions taken or planned - PIMS has implemented a file check process between Financial Aid Administrator and the Director of Administrative Services where a percentage of files is given to the Director to make sure that the aid is being processed correctly. The $2,734 has been credited to the student's account.
2020-001
We tested thirty-seven files and one credit balance was not paid back to the student. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2020-002. Cause: The condition was caused by not paying the credit balance to the student at the end of the loan period. Effect: As a result, the Institution is holding funds that need to be returned to the student. Question Costs: $5,411 Statistical sampling was not used when making sample selections. See schedule for findings and questioned costs for chart/table. Recommendation: We recommend the Institution return $5,411 to the appropriate student and increase controls over credit balances. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-002: UNPAID CREDIT BALANCE FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 FEDERAL AWARD YEAR: 2020-2021 Compliance Requirement: Special Tests and Provisions (N.) - Disbursements Criteria: An institution must pay credit balances to students within fourteen days of the creation of such credit or within fourteen days of the date the institution performs the Return calculation for withdrawn students. When a valid waiver has been obtained, an institution must pay the remaining balance on loan funds by the end of the loan period and any remaining other Title IV program funds by the end of the last payment period in the award year for which the funds were awarded (34 CFR 668.164 and 668.165). Condition: We tested thirty-seven files and one credit balance was not paid back to the student. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2020-002. Cause: The condition was caused by not paying the credit balance to the student at the end of the loan period. Effect: As a result, the Institution is holding funds that need to be returned to the student. Question Costs: $5,411 Statistical sampling was not used when making sample selections. See schedule for findings and questioned costs for chart/table. Recommendation: We recommend the Institution return $5,411 to the appropriate student and increase controls over credit balances. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Comments on findings and recommendations -The erroneous action happened due to a lack of understanding of the regulations by the Business Office. Although the Business Officer has been trained on the need to refund any aid awarded late, she missed refunding this Pell Grant belonging to a prior term even though she marked them correctly showing one from the 1st term and the other form the 2nd term. The school agrees with the auditor's finding. Actions taken or planned - Additional training is being set-up to ensure that she is properly trained and understands the regulations and the importance of following them. In addition, a new process has been created where the Business Officer provides the FAA a ledger to review every time a payment is received from a prior term. The FAA will review and make recommendations on which amounts need to e refunded to the student. The funds in question had already been refunded to the student on August 25, 2021.
2020-002
We tested thirty-seven files and identifying information was not submitted to NSLDS for transfer monitoring for one student. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by the financial aid department being unaware of the requirement. Effect: The result is the Institution would not be notified to any relevant changes in financial aid history that may affect Title IV eligibility. Question Costs: $14,538 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for chart/table. Recommendation: We recommend the Institution tighten controls surrounding the addition of students to their Transfer Monitoring List. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-003: TRANSFER STUDENT MONITORING PROCESS NOT COMPLETED FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM, FEDERAL DIRECT LOAN PROGRAM, AND FEDERAL SUPPLEMENTAL EDUCATIONAL GRANT PROGRAM ALN#: 84.063, 84.268, 84.007 FEDERAL AWARD YEAR: 2020-2021 Compliance Requirement: Special Tests and Provisions (N.) - Disbursements Criteria: An institution must request updated information from the Secretary, through the National Student Loan Data System (NSLDS) Transfer Monitoring Process, for students who transfer in from another institution during the same award year (34 CFR 668.19). Condition: We tested thirty-seven files and identifying information was not submitted to NSLDS for transfer monitoring for one student. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by the financial aid department being unaware of the requirement. Effect: The result is the Institution would not be notified to any relevant changes in financial aid history that may affect Title IV eligibility. Question Costs: $14,538 Statistical sampling was not used when making sample selections. See schedule of findings and questioned costs for chart/table. Recommendation: We recommend the Institution tighten controls surrounding the addition of students to their Transfer Monitoring List. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Comments on findings and recommendations - The finding was an oversite by the financial aid office. The FAA forgot to add the student to the Transfer Monitoring list when she was in the middle of processing the student's financial aid. The office is very aware and understands that all student's who have received prior educational credits must be added to the transfer monitoring list. The school also agrees with this finding. Actions taken or planned - As mentioned above in Finding 2021-001, the file check process will also provide a double check that those students who had credits prior to attending the Institute, have been placed on the Transfer Monitoring list.
We tested seven drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2020-003. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $2,248 Statistical sampling was not used when making sample selections. See schedule of Findings and Questioned Costs for chart/table. Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-004: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM ALN#: 84.268 FEDERAL AWARD YEAR: 2020-2021 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested seven drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2020-003. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $2,248 Statistical sampling was not used when making sample selections. See schedule of Findings and Questioned Costs for chart/table. Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Comments on findings and recommendations - The student who had the late refund was a special case. The Institute had been contacted by a constituent of the school who had concerns about the student's social media presence and the moral behavior of a Funeral Director. Her ability to seek and obtain employment came into question because she was being accused of having broken the moral code of an FD. Based on her behavior and the posted material that the student released on various sites, it was suggested that the school determine if she would even be able to practice in the profession once she graduated. Student services was called together to determine if she could continue in the program or would have to be forcibly withdrawn. The committee determined that she could not move forward at that point in time, which was the reason that her LDA and the date that the funds were returned was delayed. Regardless, we do agree that under the regulations this would be considered a late refund. Actions taken or planned - we truly do feel that this was a special circumstance, and while we understand the importance of following all regulations set forth by the Department, we also know that there are times when an FAA must wait for a school determination before they can proceed and fully understand and accept that this can lead to a finding.
2020-003
FAC accepted this audit on November 3, 2020 — management decision was due May 3, 2021.
We tested thirty-seven files and one student received a Pell grant in excess of her allowed amount. The student was eligible for $774, but received $2,323. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-001. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the student received ineligible Pell monies. Question Costs: $1,549 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table. Recommendation: We recommend the Institution refund $1,549 to the Department of Education and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2020-001: OVERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM CFDA#: 84.063 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files and one student received a Pell grant in excess of her allowed amount. The student was eligible for $774, but received $2,323. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-001. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the student received ineligible Pell monies. Question Costs: $1,549 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table. Recommendation: We recommend the Institution refund $1,549 to the Department of Education and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2020-001: Over-awarded Pell Grant PIMS agrees with the finding of the auditors that one of our students received an over award of Pell grant in the amount of $1549.00. The Institute has returned the excess Pell payment in the amount of $1549.00 to the Department of Education. In addition, the balance left by the over-award has been removed from the student?s account. It should also be noted that the PIMS received additional clarification directly from the Department of Education regarding how to calculate correct PELL amount on the R2T4. Based on these conversations regarding the similar finding on last year?s audit, PIMS FA office completed additional changes to arrive at the correct amount and submit the refund back to the Department. The findings lead to no additional monetary charges to the student, but we understand that each student deserves the right to receive the correct amount they are eligible for in all TILTE IV aid. PIMS will continue to work to make sure that the enrollment statuses are checked when each student is certified for a Pell grant moving forward. Additional reviews by the FA Director of approximately 25% percent of the Title IV recipients will continue to ensure proper oversight and increased controls over the administration of the Pell grant program.
2019-001
We tested thirty-seven files and one credit balance was not paid back to the student. We consider this finding to be an instance of non-compliance Cause: The condition was caused by not paying the credit balance to the student at the end of the loan period. Effect: As a result, the Institution is holding funds that need to be returned to the student. Question Costs: $720 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $720 to the appropriate studen and increase controls over paying credit balances. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2020-002: UNPAID CREDIT BALANCE FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Special Tests and Provisions (N.) - Disbursements Criteria: An institution must pay credit balances to students within fourteen days of the creation of such credit or within fourteen days of the date the institution performs the Return calculation for withdrawn students. When a valid waiver has been obtained, an institution must pay the remaining balance on loan funds by the end of the loan period and any remaining other Title IV program funds by the end of the last payment period in the award year for which the funds were awarded (34 CFR 668.164 and 668.165). Condition: We tested thirty-seven files and one credit balance was not paid back to the student. We consider this finding to be an instance of non-compliance Cause: The condition was caused by not paying the credit balance to the student at the end of the loan period. Effect: As a result, the Institution is holding funds that need to be returned to the student. Question Costs: $720 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: We recommend the Institution return $720 to the appropriate studen and increase controls over paying credit balances. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2020-002: Unpaid Credit Balance PIMS agrees with the findings of the auditors that one of the students reviewed had his credit balance held after the end of a loan period, which has since been refunded back to the student. This was an oversight by the Business Office. PIMS has also initiated a new internal reconciliation policy between the Business and Financial Aid offices to ensure that all students receive their refunds in a timely manner.
We tested ten drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $2,245 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for Chart/Table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2020-003: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested ten drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Question Costs: $2,245 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for Chart/Table Recommendation: We recommend the Institution increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2020-003: Late Refunds PIMS agrees with the finding of the auditors that one of the students reviewed received a late refund. Contributing to this late refund, was a technical issue with the PIMS administrative database. It was discovered after the fact that the student had discounted enrollment and should have a Title IV refund calculation completed when she did not return. During the timeframe in question, these notifications were supposed to be coming through our administrative software system but the staff (both registration and financial aid) was not aware that the system was glitching and they were not being sent or received. In addition, plans to replace the current administrative software system is currently being discussed. The withdrawal process has been changed to ensure that the FA Administrator is advised via an email from the Registrar?s office when a student withdraws form the program. Pittsburgh Institute attributes the disbursement amount to an oversight by the Financial Aid Administrator. The Administrator and Financial Aid (FA) Director will continue to work closely together to ensure that enrollment status data is up to date. This process will allow any changes to the enrollment status to be immediately available to the Financial Aid office so that aid is administered correctly.
We tested thirty-seven files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for three students. We consider these findings to be instances of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the students? enrollment dates were reported to NSLDS inaccurately or were missing. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: As effective dates have since been updated in NSLDS, we recommend the Institution increase controls over enrollment reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2020-004: INACCURATE ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 & 2019-2020 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: We tested thirty-seven files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for three students. We consider these findings to be instances of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the students? enrollment dates were reported to NSLDS inaccurately or were missing. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of Findings and Questioned Costs for chart/table Recommendation: As effective dates have since been updated in NSLDS, we recommend the Institution increase controls over enrollment reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2020-004: Inaccurate Enrollment Status Reporting PIMS agrees with the findings of the auditors that three of the students reviewed were never submitted to NSLDS to be placed on the Enrollment Reporting Roster file. PIMS has initiated a process to maintain proper start and end dates for students which is reported directly to the Financial Aid office, which includes both last date of attendance and date of determination.
FAC accepted this audit on January 15, 2020 — management decision was due July 15, 2020.
We tested thirty-seven files and one student did not receive the full amount of his allowed Pell grant. The student was eligible for $4,940, but received $4,234. Cause: The condition was caused by using an incorrect enrollment status for one payment period. Effect: The result is a student did not receive $706 of eligible Pell monies. Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution credit $706 to the student?s account and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2019-001: UNDERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM CFDA#: 84.063 FEDERAL AWARD YEAR: 2018-2019 Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files and one student did not receive the full amount of his allowed Pell grant. The student was eligible for $4,940, but received $4,234. Cause: The condition was caused by using an incorrect enrollment status for one payment period. Effect: The result is a student did not receive $706 of eligible Pell monies. Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution credit $706 to the student?s account and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2019-001: Under-awarded Pell Grant A. Comments on Findings and Recommendations: Pittsburgh Institute of Mortuary Science, Inc., hereby referred to as "PIMS", "Pittsburgh Institute", or "The Institute" agrees with the findings of the auditors that one of our students received an under award of Pell Grant in the amount of $706. B. Action Planned or Taken: PIMS has already credited the late Pell payment to the student's account on September 9, 2019. In addition, that amount has been returned to the student. Pittsburgh Institute attributes the disbursement amount to an oversight by the Financial Aid Administrator. The Administrator and Registrar will work closely together to ensure that enrollment status data is up-to-date so that aid is administered accurately. The findings lead to no monetary charges but we understand that each student deserves the right to receive the total amount they are eligible for in all Title IV aid, especially in regards to grant aid. PIMS will continue to work to make sure that enrollment status is checked when each student is certified for a Pell grant moving forward. Additionally the Chief Administrative Officer will conduct reviews approximately 25% of the Title IV recipients to ensure proper oversight and increased controls over the administration of the Pell grant program.
2018-001
We tested 37 files and one student did not receive the full amount of their Federal Direct Subsidized Loan. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is a student received an unsubsidized loan prior to receiving a full subsidized loan. Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution reclassify $500 from unsubsidized to subsidized and increase controls of packaging loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2019-002: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2018-2019 Criteria: A second year student can receive up to $4,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested 37 files and one student did not receive the full amount of their Federal Direct Subsidized Loan. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is a student received an unsubsidized loan prior to receiving a full subsidized loan. Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution reclassify $500 from unsubsidized to subsidized and increase controls of packaging loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2019-002: Under-awarded Federal Direct Subsidized Loan A. Comments on Findings and Recommendations: PIMS agrees with the findings of the auditors that one of the students reviewed had her subsidized Stafford loan amount certified incorrectly. B. Action Planned or Taken: The FA Administrator has requested a reclassification of the $500 from Unsubsidized to Subsidized loan amount. In addition, the Institute has initiated additional reviews of approximately 25% of Title IV aid recipients by the Chief Administrative Officer to increase controls of packaging loans and to ensure additional oversight and early stoppage of any trends in miscalculations in statuses and/or amounts.
We tested 37 files and identifying information was not submitted to NSLDS for monitoring for two students. Cause: The condition was caused by oversights in the financial aid department. Effect: The result is the Institution would not be notified to any relevant changes in financial aid history that may affect Title IV eligibility. Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution implement procedures to add transfer students to their Transfer Monitoring List. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2019-003: TRANSFER STUDENT MONITORING PROCESS NOT COMPLETED FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANT PROGAM, FEDERAL PELL GRANT PROGRAM, FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.007, 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 Criteria: An institution must request updated information from the Secretary, through the National Student Loan Data System (NSLDS) Transfer Monitoring Process, for students who transfer in from another institution during the same award year (34 CFR 668.19). Condition: We tested 37 files and identifying information was not submitted to NSLDS for monitoring for two students. Cause: The condition was caused by oversights in the financial aid department. Effect: The result is the Institution would not be notified to any relevant changes in financial aid history that may affect Title IV eligibility. Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution implement procedures to add transfer students to their Transfer Monitoring List. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2019-003: Transfer Student Monitoring Process Not Completed A. Comments on Findings and Recommendations: PIMS agrees with the findings of the auditors that two of the students reviewed were never submitted to NSLDS to be placed on the Transfer Monitoring list and acknowledges that this error could have led to the Institute not being notified regarding any relevant changes in the financial aid history, which could have affected the student's Title IV eligibility. B. Action Planned or Taken: The CAO has worked with the Administrator to stress the importance of the process, and has provided the Administrator with a checklist of things that must be completed for each Title IV eligible student to be used for all students who have completed a FAFSA and are seeking Title IV financial aid.
We tested fourteen drop students and found one incorrect refund calculation. Cause: The condition was caused by not properly adjusting the Pell grant to account for modular classes where attendance had not begun, prior to performing the refund calculation and by listing loans as disbursed rather than could have been disbursed in Step 2 of the Return to Title IV calculation Effect: The result is the Institution retained funds that should have been refunded funds to the Department of Education. Statistical sampling was not used when making sample selections. Recommendation: As $2,597 has since been refunded to the Department of Education, we recommend the Institution tighten controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2019-004: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM & FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 Criteria: An institution must use the Return of Title IV refund calculation (34 CFR 668.22). Condition: We tested fourteen drop students and found one incorrect refund calculation. Cause: The condition was caused by not properly adjusting the Pell grant to account for modular classes where attendance had not begun, prior to performing the refund calculation and by listing loans as disbursed rather than could have been disbursed in Step 2 of the Return to Title IV calculation Effect: The result is the Institution retained funds that should have been refunded funds to the Department of Education. Statistical sampling was not used when making sample selections. Recommendation: As $2,597 has since been refunded to the Department of Education, we recommend the Institution tighten controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Response to finding 2019-004: Incorrect Refund Calculation A. Comments on Findings and Recommendations: PIMS agrees with the findings of the auditors that one of the students reviewed did not have their Pell properly adjusted to account for modular classes in which attendance had not begun prior to performing the refund calculation and by listing the loans as disbursed rather than could have been disbursed. B. Action Planned or Taken: The $2,597 refund has been returned to the Department of Education. The CAO and Administrator will work together to review each refund calculation to fix errors as they happen.
2018-003
FAC accepted this audit on September 19, 2018 — management decision was due March 19, 2019.
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2017-002
FAC accepted this audit on November 20, 2017 — management decision was due May 20, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on December 12, 2016 — management decision was due June 12, 2017.
GSA_MIGRATION
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