Ivy Tech Community College of IndianaHigher Education

FINDING 2025-001 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Program: TRIO Talent Search Assistance Listings Number: 84.044 Federal Award Number and Year (or Other Identifying Number): P044A220683 Compliance Requirement: Eligibility Audit Findings: Significant Deficiency, Other Matters This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-002. Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Eligibility compliance requirements. The following deficiencies over determination and noncompliance were noted:  For TRIO Talent Search, 2 of the 16 students from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 16 students from the Northwest (Lake) Campus of the College could not provide evidence that the participant was a citizen, national, or permanent resident of the United States or in the United States for other than a temporary purpose. The lack of internal controls was isolated to the Northwest (Lake) Campus TRIO Talent Search program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 646.3 states: "A student is eligible to participate in a Student Support Services project if the student meets all of the following requirements: INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Is a citizen or national of the United States or meets the residency requirements for Federal student financial assistance. (b) Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution. (c) Has a need for academic support as determined by the grantee, in order to pursue successfully a postsecondary educational program. (d) Is– (1) A low-income individual; (2) A first generation college student; or (3) An individual with disabilities." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Eligibility compliance requirement. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 19

FINDING 2025-002 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-003. Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors on the fiscal year 2024 Annual Performance Report (APR) were noted:  For TRIO Student Support Services at the Indianapolis Campus, key line items were tested for 24 students. For 1 student, field 31 "Undergraduate Degree/Certificate Completed at Grantee Institution" was inaccurately reported.  For TRIO Student Support Services at the Northwest (Lake) Campus, key line items were tested for 22 students. o For 1 student, field 15 "Eligibility" was inaccurately reported. o For 2 students, field 18 "Date of First Project Service" was inaccurately reported. o For 1 student, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 7 students, field 23 "Enrollment Status (at end of academic year)" was inaccurately reported. o For 1 student, field 24 "Academic Standing" was inaccurately reported. o For 3 students, field 31 "Undergraduate Degree/Certificate Completed at Grantee Institution" was inaccurately reported.  For TRIO Student Support Services at the Richmond Campus, key line items were tested for 25 students. o For 2 students, field 17 "First Enrollment Date (at grantee institution)" was inaccurately reported. INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) o For 1 student, field 22 "Participant Status (during academic year)" was inaccurately reported. o For 8 students, field 23 "Enrollment Status (at end of academic year)" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported.  For TRIO Talent Search at the Northwest (Lake) Campus, key line items were tested for 40 students. o For 10 students, the College could not provide supporting documentation for item A1 "Persisted in school for the next academic year at the next grade level or graduated high school." o For 2 students, the College inaccurately reported that the students persisted in the next academic year at the next grade level; however, the students did not advance to the next grade level.  For TRIO Upward Bound at the Indianapolis Campus, key line items were tested for 10 students. For 1 student, field 17 "Reading Language Arts or Math Proficiency Not Achieved" was inaccurately reported.  For TRIO Upward Bound at the Muncie Campus, key line items were tested for 9 students. o For 3 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "Reading Language Arts or Math Proficiency Not Achieved" was inaccurately reported. o For 1 student, field 19 "Pre-Algebra or Algebra Course Not Successfully Completed by Beginning of 10th Grade" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at four of the five campuses that were reported on the TRIO Cluster program during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under § 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that the TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal controls, the College cannot ensure reporting for the TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-001 Subject: Economic Adjustment Assistance - Special Tests and Provisions - Wage Rate Requirements Federal Agency: US Department of Commerce Federal Program: Economic Adjustment Assistance Assistance Listings Number: 11.307 Federal Award Number and Year (or Other Identifying Number): 06-79-06301 URI: 116544 Pass-Through Entity: Direct Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College in order to ensure compliance with the following compliance requirement: Special Tests and Provisions - Wage Rate Requirement. The College could not provide documentation or evidence to verify a review that the weekly certified payrolls were submitted by the contractor. The lack of effective internal controls was an isolated issue to one contractor during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The College's management was unable to provide documentation to verify a review that certified payrolls were submitted by the contractor due to policies and procedures not being adequate to retain the documentation for the special tests and provisions - wage rate requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the College cannot ensure the wage rate requirement is met. Noncompliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs is retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-002 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted:  For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted:  For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported.  For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported.  For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported.  For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2024-004 Subject: TRIO Cluster - Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Federal Agency: US Department of Education Federal Program: Upward Bound Program Assistance Listings Number: 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P047A221086, P047A221077 Compliance Requirement: Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement. Applications for 15 participants in the Upward Bound Program were tested for evidence of review by 2 members of the TRIO staff. For 2 of the 15 applications tested, both from the Indianapolis campus, there was no documentation of a dual review at the Indianapolis campus. The lack of internal controls was isolated to one campus during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The College's management was unable to provide evidence of review of applications for the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for the TRIO Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement could have resulted in the loss of federal funds to the College. INDIANA STATE BOARD OF ACCOUNTS 23 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Return of Title IV Funds Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant, Federal Direct Student Loans Assistance Listings Numbers: 84.007, 84.063, 84.268 Federal Award Number and Year (or Other Identifying Number): FY 2022 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds Audit Findings: Material Weakness, Other Matters Condition and Context The College had not designed, nor implemented an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions - Return of Title IV Funds compliance requirement. For 2 of 25 (8 percent) return of Title IV funds tested, the amount returned to the Department of Education was incorrect. The College completed an initial return of Title IV funds and properly posted the full amount of aid to be returned to the students' accounts. During an internal review, the College discovered an error in the initial calculation and therefore calculated a new return of Title IV funds. When the subsequent calculation was performed, the College once again posted the total amount of aid to be returned to each student's account. As a result, the College incorrectly returned too much in Title IV funds to the Department of Education in the amounts of $113 and $546 for the first and second errors, respectively. In addition, this caused both students' accounts to reflect a balance due to the College that should not have been owed. The lack of internal controls and noncompliance were systemic issues throughout the audit period; however, these were isolated to students for which a corrective calculation for return of Title IV funds was performed. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 668.22(g) states in part: "Return of unearned aid, responsibility of the institution. (1) The institution must return, in the order specified in paragraph (i) of this section, the lesser of ? (i) (ii) Cause The total amount of unearned title IV assistance to be returned as calculated under paragraph (e)(4) of this section; or An amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of title IV grant or loan assistance that has not been earned by the student, as described in paragraph (e)(3) of this section. . . ." Management had not developed a system of internal control that would have ensured procedures were in place in order to comply with the provisions of federal statutes, regulations, and the terms and conditions of the federal award in relation to the Special Tests and Provisions - Return of Title IV Funds compliance requirement. The College should have considered the original amount of aid to be returned that had already been posted to each student's account. The College should have posted the additional amount of aid to be returned to the students' accounts based upon the net difference between the original calculation and the corrective calculation performed for each student. Effect The failure to design and implement an effective internal control system enabled material noncompliance to remain undetected. As a result, the College returned too much in Title IV funds to the Department of Education as outlined in the Condition and Context. Questioned Costs There were no questioned costs identified. Recommendation We recommended the College's management design and implement a system of internal control related to procedures for calculating the return of Title IV funds to ensure appropriate amounts are returned to the Department of Education and are posted to students' accounts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response It is the College's responsibility to administer its student financial assistance programs in a manner that both complies with applicable federal regulations and guidelines as well as ensures that, when necessary, the appropriate amount of unearned financial assistance is returned to the Title IV programs. 34 CFR 668.22(g) states in part: "Return of unearned aid, responsibility of the institution. (1) The institution must return, in the order specified in paragraph (i) of this section, the lesser of ? (i) (ii) Cause The total amount of unearned title IV assistance to be returned as calculated under paragraph (e)(4) of this section; or An amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of title IV grant or loan assistance that has not been earned by the student, as described in paragraph (e)(3) of this section. . . ." Management had not developed a system of internal control that would have ensured procedures were in place in order to comply with the provisions of federal statutes, regulations, and the terms and conditions of the federal award in relation to the Special Tests and Provisions - Return of Title IV Funds compliance requirement. The College should have considered the original amount of aid to be returned that had already been posted to each student's account. The College should have posted the additional amount of aid to be returned to the students' accounts based upon the net difference between the original calculation and the corrective calculation performed for each student. Effect The failure to design and implement an effective internal control system enabled material noncompliance to remain undetected. As a result, the College returned too much in Title IV funds to the Department of Education as outlined in the Condition and Context. Questioned Costs There were no questioned costs identified. Recommendation We recommended the College's management design and implement a system of internal control related to procedures for calculating the return of Title IV funds to ensure appropriate amounts are returned to the Department of Education and are posted to students' accounts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. Auditor's Response It is the College's responsibility to administer its student financial assistance programs in a manner that both complies with applicable federal regulations and guidelines as well as ensures that, when necessary, the appropriate amount of unearned financial assistance is returned to the Title IV programs.

FINDING 2021-001 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Disbursements to or on Behalf of Students Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans CFDA Numbers: 84.007, 84.033, 84.063, 84.268 Federal Award Number and Year (or Other Identifying Number): FY 2021 Compliance Requirement: Special Tests and Provisions - Disbursements to or on Behalf of Students Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Disbursements to or on Behalf of Students compliance requirement. A sample of 25 students was tested for Disbursements to or on Behalf of Students. Due to separate issues within the financial aid system, errors were identified in both the timing of disbursements and in the monitoring of transfer students. Timing of Disbursements The College's cohort default rate was not under 15 percent for each of the three most recent fiscal years. Due to this, during the audit period, the College was required to wait 30 days to disburse loans to first-year undergraduate students who were first-time borrowers. One student reviewed, that met this criterion, received a Direct Loan disbursement 20 days after the start of the term. The early disbursement was a result of system disbursing 30 days from the start of term, without consideration for later start modules. Beginning in the 21-22 award year, the College developed a process to evaluate first-time, firstyear students to ensure the disbursement date is moved 30 days from the student's earliest class start date within the system module. Review of Transfer Students One transfer student was not properly monitored by the College to ensure the financial aid history was requested within the appropriate time frame. The lack of internal controls and noncompliance were systemic issues, which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 685.303(b)(5)(i) states in part: "If a student is enrolled in the first year of an undergraduate program of study and has not previously received a Direct Subsidized Loan, a Direct Unsubsidized Loan, a Subsidized or Unsubsidized Federal Stafford Loan, or a Federal Supplemental Loan for Students, a school may not disburse the proceeds of a Direct Subsidized or Direct Unsubsidized Loan until 30 days after the first day of the student's program of study . . ." 34 CFR 668.19(b) states: "(1) If a student transfers from one institution to another institution during the same award year, the institution to which the student transfers must request from the Secretary, through NSLDS, updated information about that student so it can make the determinations required under paragraph (a) of this section; and (2) The institution may not make a disbursement to that student for seven days following its request, unless it receives the information from NSLDS in response to its request or obtains that information directly by accessing NSLDS, and the information it receives allows it to make that disbursement." Cause Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Disbursements to or on Behalf of Students compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance with the Special Tests and Provisions - Disbursements to or on Behalf of Students compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management establish a system of internal control related to the grant agreement and the compliance requirement listed above. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2021-002 Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Return of Title IV Funds Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans CFDA Numbers: 84.007, 84.063, 84.268 Federal Award Number and Year (or Other Identifying Number): FY 2021 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Return of Title IV Funds compliance requirement. A sample of 45 students was tested for Return of Title IV Funds. Testing included a recalculation of the returns for withdrawn students and the return of aid for those students. Multiple errors in the calculations of aid to be returned and in the actual return of aid were noted. In total, 17 errors were identified across 16 different students as follows: 1. The incorrect amount of Institutional Charges was used in the calculation of aid to be returned for 6 students. For 1 student, the calculation included charges for books which had been removed from the student's account prior to withdrawal. For the other 5 students, the College included all sales tax charged to the student. A portion of the sales tax in each instance was the result of Other Bookstore Charges that should not have been included in the calculation. 2. The incorrect amount of Aid That Could Have Been Disbursed in the calculation for 2 returns. 3. The incorrect withdrawal date was used in the calculation for 4 returns. 4. One return was subsequently reversed two months after it was posted. The College unlocked the student's record to make changes which resulted in the Pell amount being redisbursed. 5. An incorrect amount to be returned was posted to 2 students' accounts. 6. For 2 returns tested, the refund was not posted within 45 days of the College's determination that the student withdrew. The refunds were posted in 48 and 77 days, respectively, after the College identified that the student had withdrawn. The lack of internal controls and noncompliance were systemic issues, which occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . . " 34 CFR 668.22(a)(2)(i) states in part: ". . . a student is considered to have withdrawn from a payment period or period of enrollment if - (A) In the case of a program that is measured in credit hours, the student does not complete all of the days in the payment period or period of enrollment that the student was scheduled to complete; . . ." 34 CFR 668.22(c)(1)(ii) states: "The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw;" 34 CFR 668.22(f)(2)(i) states: "The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period." 34 CFR 668.22(e)(1) states: "General. The amount of title IV grant or loan assistance that is earned by the student is calculated by - (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date." 34 CFR 668.22(e)(4) states in part: ". . . The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (I)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew." 34 CFR 668.22(g) states in part: ". . . (1) The institution must return, in the order specified in paragraph (i) of this section, the lesser of - i. The total amount of unearned title IV assistance to be returned as calculated under paragraph (e)(4) of this section; or ii. An amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of title IV grant or loan assistance that has not been earned by the student, . . ." 34 CFR 668.173(b) states in part: ". . . In accordance with procedures established by the Secretary or FFEL Program lender, an institution returns unearned title IV, HEA program funds timely if - (1) The institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; . . ." Cause Management had not developed a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Return of Title IV Funds compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management establish a system of internal control related to the grant agreement and the compliance requirement listed above. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2020-001 Subject: TRIO Cluster - Reporting Federal Agency: Department of Education Federal Program: TRIO Student Support Services CFDA Number: 84.042 Federal Award Numbers or Years (or Other Identifying Numbers): P042A150768, P042A150724 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding of 2019-002 from the immediately prior audit report. Condition and Context An effective internal control system was not in place for the Student Support Services programs located at the East Central Region and Northwest campuses to ensure compliance with the grant agreement and the Reporting compliance requirement. The Student Support Services (SSS) program is required to submit an Annual Performance Report (APR) by December 16, 2019, for activity in the 2018-2019 award year to the Department of Education. The APR includes the Record Structure for Participant List (participant database). The participant database consists of all participants in the program with 37 field codes, which describe the demographic information, eligibility and cohort status, and project entry information; participant's status and academic status; and academic progress/persistence. For the East Central Region campus SSS program, a sample of thirty-five participants was selected to verify the information in the participants' files to the participant database. Of the participants tested, the following errors were noted: ? Six had the incorrect eligibility status. ? Four had the incorrect date of first project service. ? One had the incorrect grade level at entry to the program. ? One had the incorrect undergraduate degree/certificate completed at grantee institution status. For the Northwest campus SSS program, a sample of forty-two participants was selected to verify the information in the participants' files to the participant database. Of the participants tested, the following errors were noted: ? Three had the incorrect undergraduate degree/certificate completed at grantee institution status. The ineffectiveness of the internal controls and the noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 80.40(b)(1) states in part: "Grantees shall submit annual performance reports . . ." 34 CFR 646.32(c) states in part: "Recordkeeping: A grantee must maintain participant records that show - (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause Management had not developed a system of internal controls that segregated key functions to ensure compliance with the grant agreements and the Reporting compliance requirement. Effect The failure to establish an effective internal control system which would include segregation of duties, enabled noncompliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management establish internal controls related to the grant agreement and the compliance requirement listed above. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Subject: TRIO Cluster - Eligibility Federal Agency: Department of Education Federal Program: TRIO Student Support Services CFDA Number: 84.042 Federal Award Numbers or Years (or Other Identifying Numbers): P042A150724, P042A151019 Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat of Finding 2018-004 from the immediately prior report. Condition An effective internal control system, which would include segregation of duties, was not in place at Central Indiana and East Central Region campuses of the College to ensure compliance with the grant agreement and the Eligibility compliance requirement. There was no review of eligibility beyond the Director's initial eligibility determination at two region campuses. A sample of ten students was selected to verify eligibility at the East Central Region campus. Of the students tested, two were not enrolled or accepted for enrollment for the 2017-2018 academic year. Context The lack of controls was a systemic problem throughout the audit period at the Central Indiana and East Central Region campuses until March 2018 when corrective action was implemented. The noncompliance was a systemic issue throughout the audit period at the East Central Region campus of the College. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 646.3 states in part: "A student is eligible to participate in a Student Support Services project if the student meets all of the following requirements: . . . (b) Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution. . . ." Cause Management had not developed a system of internal controls that segregated key functions that would have ensured compliance with the Eligibility compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance with the Eligibility compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management establish controls related to the grant agreement and the compliance requirement listed above. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Subject: TRIO Cluster - Reporting Federal Agency: Department of Education Federal Programs: TRIO Student Support Services CFDA Number: 84.042 Federal Award Numbers or Years (or Other Identifying Numbers): P042A150724, P042A150768, P042A151019 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding of 2018-005 from the immediately prior audit report. Condition An effective internal control system was not in place at the East Central Region, Lake County, and Central Indiana campuses to ensure compliance with the grant agreement and the Reporting compliance requirement. The Student Support Services program was required to submit an Annual Performance Report (APR) by March 8, 2019, for activity in the 2017-2018 award year to the Department of Education. The APR includes the Record Structure for Participant List (participant database). The participant database consists of all participants in the program with 37 field codes which describe the demographic information, eligibility, and cohort status and project entry information; participant's status and academic status; and academic progress/persistence. A sample of 29 participants was selected to verify the information in the participants' files to the participant database. Of the participants tested the following errors were noted: o One had the incorrect date of first enrollment. o One had the incorrect grade level at entry to the program. o Three had the incorrect enrollment status at the end of the 2017-2018 academic year. o One had the incorrect academic standing status at the end of the 2017-2018 academic year. o Four had the incorrect grade level at the end of the 2017-2018 academic year. o Two tested had the incorrect graduation date. Of the errors noted all but the two incorrect graduation dates have been corrected and verified in the Record Structure for Participant List. Context The ineffectiveness of controls and noncompliance were systemic problems throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 80.40(b)(1) states in part: "Grantees shall submit annual performance reports . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show ? (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause Management had not developed a system of internal controls that segregated key functions to ensure compliance with the grant agreements and the Reporting compliance requirement. Effect The failure to establish an effective internal control system, which would include segregation of duties, enabled noncompliance with the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management establish controls related to the grant agreement and the compliance requirement listed above. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Return of Title IV Funds Federal Agency: Department of Education Federal Programs: Federal Pell Grant, Federal Direct Student Loans CFDA Numbers: 84.063, 84.268 Federal Award Number or Year (or Other Identifying Number): FY 2019 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds Audit Findings: Significant Deficiency, Other Matters Condition The College had not established an effective internal control system to ensure compliance with the grant agreement and the Special Tests and Provisions - Return of Title IV Funds compliance requirement. A sample of 45 return of funds calculations (returns) was selected for review. Of the returns tested, the following 4 errors were noted: o One return used the incorrect withdrawal date, resulting in the College returning too little in Pell funds. o One return used the incorrect number of break days, resulting in the College returning too much in Loan funds. o One return used an incorrect dollar amount for institutional charges, resulting in the College returning too much in Loan funds. o One return used the incorrect amount of aid that could be disbursed, resulting in the College incorrectly issuing a post-withdrawal disbursement instead of returning Loan funds. Additionally the following two errors were noted: o One return was correctly calculated, but a larger incorrect amount was posted to the student's account, resulting in the College returning too much in Loan Funds. o One return, for a student that completed the period of enrollment, was incorrectly processed, resulting in the College returning Pell funds. Context The ineffectiveness of controls and noncompliance related to the Special Test and Provision - Return of Title IV Funds compliance requirement were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 668.22(a)(2)(i) states in part: ". . . a student is considered to have withdrawn from a payment period or period of enrollment if ? (A) In the case of a program that is measured in credit hours, the student does not complete all of the days in the payment period or period of enrollment that the student was scheduled to complete. . . ." 34 CFR 668.22(c)(1)(ii) states: "The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw." 34 CFR 668.22(f)(2)(i) states: "The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the a payment period or period of enrollment and the number of calendar days completed in that period." 34 CFR 668.22(g) states in part: "(1) The institution must return, in the order specified in paragraph (i) of this section, the lesser of ? (i) The total amount of unearned title IV assistance to be returned as calculated under paragraph (4) of this section; or (ii) An amount equal to the total institutional charged incurred by the student for the payment period or period of enrollment multiplied by the percentage of title IV grant or loan assistance that has not been earned by the student. . . ." Cause Management had not developed a system of internal controls would have ensured compliance with the Special Tests and Provision - Return of Title IV Funds compliance requirement. Effect The failure to establish an effective internal control system enabled noncompliance with the Special Tests and Provisions - Return of Title IV Funds compliance requirement. Unearned Pell grants and Student Loans were incorrectly calculated or posted and thus, incorrect amounts were returned or provided as a post-withdrawal disbursement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management establish effective controls related to the grant agreement and the compliance requirement listed above. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

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