EIN: 352357683
UEI: RBHCY8PPJVS9
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 30, 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 December 30, 2026 (130 days from today).
What is a management decision? →Item 2025-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In accordance with the Uniform Grant Guidance for student financial assistance programs and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, institutions are required to report enrollment information under the Pell grant via the NSLDS. Institutions are responsible for accurately and timely reporting the OPEID number, enrollment effective date, enrollment status and certification date. Out of a sample of six students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. In addition, four students did not have the correct enrollment effective date submitted to NSLDS. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures did not adequately verify the information was submitted to the NSLDS timely and accurately. Finding is a repeat of finding 2024-001 in the immediately prior audit. Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in changes to future awards to the student. We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2025-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In accordance with the Uniform Grant Guidance for student financial assistance programs and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, institutions are required to report enrollment information under the Pell grant via the NSLDS. Institutions are responsible for accurately and timely reporting the OPEID number, enrollment effective date, enrollment status and certification date. Out of a sample of six students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. In addition, four students did not have the correct enrollment effective date submitted to NSLDS. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures did not adequately verify the information was submitted to the NSLDS timely and accurately. Finding is a repeat of finding 2024-001 in the immediately prior audit. Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in changes to future awards to the student. We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Corrective Action Plan (CAP): The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (92 days and 66 days). The statuses of both students are correct with NSLDS. Student 1: Student earned all F grades during the fall 2024 trimester. The student's status was changed to withdrawal in the internal student information system on January 17, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. Student 2: Student was a non-returner in the spring 2025 trimester. The student's status was changed to withdrawal in the internal student information system on January 21, 2025. This change was not communicated to NSLDS until the March 2025 enrollment report, due to issues with the February 2025 enrollment report. The College acknowledges this repeat finding and recognizes that, although the gap was narrowed days beyond tolerance, the prior corrective action plan did not fully resolve the underlying cause of late NSLDS reporting. The previous plan relied primarily on manual identification and status-change processes within the student information system, which remained vulnerable to human error and processing delays. To address this gap, the college will implement a secondary review checkpoint that flags students with status changes in the student information system to ensure timely transmission to NSLDS. To prevent additional recurrences, the College has implemented a monthly reconciliation procedure between the Registrar's Office and the Financial Aid Office, replacing the prior plan's reliance on manual status-chang communication alone. Each month, the Registrar's Office provides a student status change report to the Financial Aid Office. The Financial Aid Office then reconciles each status change against the institution's NSLDS submission history to confirm timely and accurate reporting. This added verification step, paired with documented recordkeeping of each reconciliation cycle, directly addresses the root cause of the repeat finding by introducing a cross-office check that does not depend solely on a single manual status update being correctly carried through to NSLDS reporting.
2024-001
Item 2025-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed within the maximum time allowed for two students that required a return of funds. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the Title IV worksheet was completed timely. Finding is a repeat of finding 2024-002 in the immediately prior audit. Not timely preparing a calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed timely to ensure the processing of returns is completed within the required time frame. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2025-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed within the maximum time allowed for two students that required a return of funds. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the Title IV worksheet was completed timely. Finding is a repeat of finding 2024-002 in the immediately prior audit. Not timely preparing a calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed timely to ensure the processing of returns is completed within the required time frame. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Corrective Action Plan (CAP): The College has identified that the dates of Return of Title IV Calculations and amounts (in one case) were out of compliance. The return calculations for both students identified through this audit have been completed and corrected to reflect the correct return amounts, if appropriate. Student 1: Student initiated an official withdrawal on October 5, 2024, and the withdrawal was processed on that date. A notification of student status was not received in the financial aid office in order to trigger an R2T4 calculation. This student's calculation was performed at the end of the fall 2024 term with the end of term processing, resulting in 89 days passing from notification to completion of R2T4. This instance resulted in an automatic trigger being built into the student information system, which sends an email to the financial aid office for each student when their status changes from active to withdrawal. Student 2: Student initiated an official withdrawal on February 13, 2025, and the withdrawal was processed on that date. The R2T4 calculation was not performed on this student until the end of spring 2025 term processing, resulting in 96 days passing from notification to completion of R2T4. Due to delayed calculations on these students, CMN will continue to work with financial aid staff and the registrar's office to streamline communication on withdrawals and students who complete the term with all F/NP grades, as indicated in CMN policy. CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. Additionally, Enrollment Management notifies all faculty by email at the beginning of the term and again prior to final grades being submitted that electronic notification must be sent by the faculty to financial aid in order to alert the financial aid office of the date of last academic engagement for students who earn an For NP grade. For the current audit period, the Director of Enrollment Management and the Financial Aid Coordinator work together to review a final grade report for all students and identify those who need R2T4 calculations based on that review. Both the director and coordinator sign the working documents to indicate that it has been reviewed by both parties. We will continue with this process and will refine as necessary, but we anticipate that this will resolve the issue of calculations not having been performed on students with all F/NP grades at the end of the term.
2024-002
Item 2025-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Out of a sample of 14 students who received Federal Pell Grants during the audit period, six students did not have the correct disbursement date submitted to the COD system, resulting in a difference of four days between the dates submitted to the COD system and the actual dates the funds were disbursed. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Finding is a repeat of finding 2024-003 in the immediately prior audit. Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2025-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Out of a sample of 14 students who received Federal Pell Grants during the audit period, six students did not have the correct disbursement date submitted to the COD system, resulting in a difference of four days between the dates submitted to the COD system and the actual dates the funds were disbursed. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Review procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Finding is a repeat of finding 2024-003 in the immediately prior audit. Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Corrective Action Plan (CAP): The College operates under a just- in-time (JIT) cash management model for Title IV funds, in which the disbursement date reported to COD and the date funds are credited to the student's ledger are intended to occur on the same day. Under this model, the CMN draws down Pell grant funds in conjunction with disbursing those funds to the student, rather than disbursing from institutional funds in advance of drawdown. This approach is designed to ensure the College does not hold excess cash on hand, consistent with cash management requirements under 34 CFR 668.164. The College has reviewed the six disbursements identified in this finding and confirmed that, in each instance, the COD submission was processed on schedule, but the corresponding batch process that credits funds to the student ledger ran four days later than intended, resulting in a misalignment between the reported disbursement date and the actual date the student was credited. The College has reviewed the timing and sequencing of COD submissions and ledger transactions with the Bursar's office and the Financial Aid office to ensure both are scheduled and performed on the same day. The existing weekly reconciliation process between Financial Aid and the Bursar's office will be expanded to include a verification that the disbursement date on the ledger matches the COD disbursement date. The College notes that this finding reflects a single disbursement- timing discrepancy across the sample, a reduction in both scope and recurrence compared to findings identified in prior audit periods, and reflects continued improvement in the College's cash management and COD reporting controls.
2024-003
Item 2025-004 – Special Tests: Title IV Eligibility Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Title 34 CFR 668.34(a)(5)(ii) establishes the maximum timeframe requirement for Title IV Eligibility. For an undergraduate program measured in credit hours, the maximum timeframe to be eligible is a period no longer than 150 percent of the published length of the educational program, as measured in credit hours, or expressed in calendar time. Out of a sample of 14 students, one student was not eligible to receive aid as they exceeded the 150 percent rule but received $616 of Pell during the period. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Procedures were not in place to verify the student had not exceeded the allowable credit hours attempted. Not a repeat finding. Inaccurate disbursement of the Title IV funds to be given to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions. We recommend that the Financial Aid Coordinator institute procedures that would detect whether a student has reached the maximum number of courses to remain eligible for aid. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2025-004 – Special Tests: Title IV Eligibility Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Title 34 CFR 668.34(a)(5)(ii) establishes the maximum timeframe requirement for Title IV Eligibility. For an undergraduate program measured in credit hours, the maximum timeframe to be eligible is a period no longer than 150 percent of the published length of the educational program, as measured in credit hours, or expressed in calendar time. Out of a sample of 14 students, one student was not eligible to receive aid as they exceeded the 150 percent rule but received $616 of Pell during the period. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Procedures were not in place to verify the student had not exceeded the allowable credit hours attempted. Not a repeat finding. Inaccurate disbursement of the Title IV funds to be given to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions. We recommend that the Financial Aid Coordinator institute procedures that would detect whether a student has reached the maximum number of courses to remain eligible for aid. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Corrective Action Plan (CAP): The College has reviewed the student identified in this finding and confirmed that the student had been placed on financial aid suspension during a previous term due to exceeding the 150% maximum timeframe for program completion, but the suspension status was not reflected when the student's enrollment was subsequently evaluated, resulting in the student receiving Title IV aid for which they were not eligible during the period under audit. The College has identified that this occurred in connection with how the student's enrollment was recorded across programs within Anthology, the College's student information system, and is continuing to investigate the precise cause of the system behavior that allowed the student's Satisfacto1y Academic Progress (SAP)/150% status to not carry forward or recalculate appropriately. The aid improperly disbursed to this student has been identified, and repayment has been completed.
Item 2025-005 – Special Tests: Disbursements to or on Behalf of Students Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Title 34 CFR Section 690.62 states the amount of a student's Federal Pell Grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Out of a sample of 14 students, one student Federal Pell Grant calculation was calculated incorrectly resulting in an under award to the student. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. The College did not implement the new Federal Pell Grant calculations to include enrollment intensity. Not a repeat finding. Inaccurate calculation of the Title IV funds to be given to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute procedures that would ensure that Pell calculations are performed accurately and policy changes from the Department of Education are reviewed. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2025-005 – Special Tests: Disbursements to or on Behalf of Students Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2025 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Title 34 CFR Section 690.62 states the amount of a student's Federal Pell Grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Out of a sample of 14 students, one student Federal Pell Grant calculation was calculated incorrectly resulting in an under award to the student. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. The College did not implement the new Federal Pell Grant calculations to include enrollment intensity. Not a repeat finding. Inaccurate calculation of the Title IV funds to be given to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. We recommend that the Financial Aid Coordinator institute procedures that would ensure that Pell calculations are performed accurately and policy changes from the Department of Education are reviewed. Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Corrective Action Plan (CAP): The College has reviewed the Federal Pell Grant calculation identified in this finding and confirmed that the student's award was calculated incorrectly, resulting in an under-award, due to staff error in applying the enrollment intensity calculation under the rules in effect for the 2024-25 award year. The College has recalculated the student's award using the correct enrollment intensity methodology, and the additional Pell Grant funds owed to the student (616.00) have been disbursed. Financial Aid staff are committed to maintaining current knowledge of federal regulatory changes affecting Title IV award calculations. To support this, staff will continue to participate in NASFAA training and U.S. Department of Education webinars addressing Pell Grant calculation methodology and other regulatory updates on an ongoing basis, including specific training addressing changes to enrollment intensity calculations.
FAC accepted this audit on June 25, 2025 — management decision was due December 25, 2025.
Finding: Item 2024-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was submitted to the NSLDS timely. Repeat finding: Not a repeat finding. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2024-001 – Special Tests: Enrollment Reporting Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, two students did not have their enrollment status submitted within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was submitted to the NSLDS timely. Repeat finding: Not a repeat finding. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute procedures that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure accuracy, including training, clarifying written policies and adding automated controls when possible. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enollment status and subsequent R2T4 calculation (as noted in finding 2024-002) was delayed. Student 2: Student graduated, and status was updated with NSLDS at 69 days. Due to delayed communication and delayed reporting to NSLDS, CMN will revise institutional policy to clearly define the process and timeline for enrollment status changes. Financial aid staff will seek additional training in enrollment reporting through FSA and/or NSFAA. To further monitor compliance, CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. This electronic, automatic process will provide an additional layer of notification to the financial aid office when a student status change requires further attention.
Finding: Item 2024-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Condition / context: Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed timely for two students that required a return of funds. Additionally, the Title IV worksheet was not completed accurately for one student. There was a delay in return of Title IV funds for all three of these students that exceeded the maximum time allowed of 45 days after the date the institution determined that the student withdrew. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the Title IV worksheet was completed accurately and returns were processed timely. Repeat finding: Finding is a repeat of finding 2023-002 in the immediately prior audit. Effect: Inaccurate calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed accurately and correctly to ensure that amounts earned by students who withdraw from the College are calculated correctly to ensure timely processing of returns, if any. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2024-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of the withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Condition / context: Out of a sample of eight students who withdrew during the audit period, the Title IV worksheet was not completed timely for two students that required a return of funds. Additionally, the Title IV worksheet was not completed accurately for one student. There was a delay in return of Title IV funds for all three of these students that exceeded the maximum time allowed of 45 days after the date the institution determined that the student withdrew. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the Title IV worksheet was completed accurately and returns were processed timely. Repeat finding: Finding is a repeat of finding 2023-002 in the immediately prior audit. Effect: Inaccurate calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed accurately and correctly to ensure that amounts earned by students who withdraw from the College are calculated correctly to ensure timely processing of returns, if any. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
The College has identified that the dates of Return of Title IV Calculations and amounts (in one case) were out of compliance. The return calculations for all three students identified through this audit have been completed and corrected to reflect the correct return amounts, if appropriate. Student 1: After changing from an attendance-taking institution to a non-attendance taking institution, this student was identified during the audit as a student who may not have completed the term due to all F/NP grades. Calculation was completed and a return was made based on the midpoint date of the spring term. Student 2: After changing from an attendance-taking institution to a non-attendance taking institution, this student was identified during the audit as a student who may not have completed the term due to all F /NP grades. Calculation was completed and a return was made based on the midpoint date of the spring term. Student 3: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enrollment status (as noted in fmding 2024-001) and subsequent R2T4 calculation was delayed. Calculation was completed and a return was made based on the date indicated in the official withdrawal documents. Due to delayed calculations on these three students, CMN will continue to work with fmancial aid staff and the registrar's office to streamline communication on withdrawals and students who complete the term with all F/NP grades, as indicated in CMN policy. CMN has already worked with Anthology (student information system)'to provide electronic triggers to the fmancial aid office when a student status changes from active to drop/withdrawal. Additionally, Enrollment Management notifies all faculty by email at the beginning of the term and again prior to fmal grades being submitted that electronic notification must be sent by the faculty to financial aid in order to alert the fmancial aid office of the date oflast academic engagement for students who earn an For NP grade. For the current audit period, the Director of Enrollment Management and the Financial Aid Coordinator work together to review a final grade report for all students and identify those who need R2T4 calculations based on that review. Both the director and coordinator sign the working documents to indicate that it has been reviewed by both parties. We will continue with this process and will refme as necessary, but we anticipate that this will resolve the issue of calculations not having been performed on students with all F /NP grades at the end of the term.
2023-002
Finding: Item 2024-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Condition / context: Out of a sample of 27 students who received Federal Pell Grants during the audit period, nine students did not have the correct disbursement date submitted to the COD system. The discrepancies in dates submitted and actual dates disbursed ranged from one to five days. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Repeat finding: Not a repeat finding. Effect: Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. Recommendation: We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2024-003 – Reporting: Pell Grant Disbursement Data Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2024 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: In the management and reporting of Pell Grants, institutions are required to submit Pell Grant origination and disbursement records to the U.S. Department of Education's Common Origination & Disbursement (COD) system. Institutions must report student disbursement data within 15 calendar days after making a disbursement or upon becoming aware of the need to adjust previously reported or expected disbursement data. The disbursement record must accurately report both the actual disbursement date and the amount disbursed. Condition / context: Out of a sample of 27 students who received Federal Pell Grants during the audit period, nine students did not have the correct disbursement date submitted to the COD system. The discrepancies in dates submitted and actual dates disbursed ranged from one to five days. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the correct disbursement dates were submitted to the COD system. Repeat finding: Not a repeat finding. Effect: Inaccurate disbursement date reporting can impact reconciliation efforts, potentially leading to compliance issues, administrative inefficiencies, and delays in financial aid processing. Recommendation: We recommend that the Financial Aid Coordinator coordinate with the bursar and add procedures to ensure the accuracy of disbursement date reporting. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
The instances identified in this finding represent individuals who, in several cases, were processed in the same batches ( e.g., COD date 9/28/23, disbursement date on ledger 10/3/23, and COD date 11/3/23, disbursement date 11/8/23). CMN recognizes the importance of disbursing funds to student accounts on the date that funds are stated to be disbursed through COD. While there have been instances of funds not being available in COD in a timely manner, the financial aid coordinator and bursar will work together to ensure these disbursements are completed on the same date in order to remain compliant with stated CMN policy.
FAC accepted this audit on May 30, 2024 — management decision was due November 30, 2024.
Finding: Item 2023-001 – Special Tests: Disbursements to or on Behalf of Students Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2023 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Title 34 CFR Section 690.62 states the amount of a student's Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Condition / context: Out of a sample of eleven students who received Federal Pell Grants during the audit period, three students were not calculated correctly resulting in over and under awarded amounts. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: One student was close to the lifetime limit of Federal Pell Grants but was still eligible for a Federal Pell Grant in the current year. The other two students' Federal Pell Grants were not calculated appropriately based on the workload shown on the transcripts for the students. Additionally, there was a lack of review to ensure the students' Federal Pell Grants were calculated correctly. Repeat finding: Not a repeat finding. Effect: Three students did not receive the proper amount of Federal Pell Grant funds based on their eligibility. Recommendation: We recommend that the Financial Aid Coordinator institute a review procedure that would ensure that the Pell Grant amounts disbursed are calculated correctly. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2023-001 – Special Tests: Disbursements to or on Behalf of Students Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2023 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Title 34 CFR Section 690.62 states the amount of a student's Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Condition / context: Out of a sample of eleven students who received Federal Pell Grants during the audit period, three students were not calculated correctly resulting in over and under awarded amounts. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: One student was close to the lifetime limit of Federal Pell Grants but was still eligible for a Federal Pell Grant in the current year. The other two students' Federal Pell Grants were not calculated appropriately based on the workload shown on the transcripts for the students. Additionally, there was a lack of review to ensure the students' Federal Pell Grants were calculated correctly. Repeat finding: Not a repeat finding. Effect: Three students did not receive the proper amount of Federal Pell Grant funds based on their eligibility. Recommendation: We recommend that the Financial Aid Coordinator institute a review procedure that would ensure that the Pell Grant amounts disbursed are calculated correctly. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Pell calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand all aspects of calculating awards, as well as staying up to date on regulatory changes through our student information system. In addition to more training in this area, priority will be placed on rechecking and auditing Pell awards so that they are reviewed during the award year. Staff has already begun reviewing fall 2023 Pell awards for accuracy and will continue to review awards as terms move forward.
Finding: Item 2023-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2023 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Condition / context: Out of a sample of four students who withdrew during the audit period, the Title IV worksheet was not completed correctly for two students that required a return of funds. Additionally, there was a delay in return of Title IV funds for both students that exceeded the maximum time allowed of 45 days after the date the institution determined that the student withdrew. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the Title IV worksheet was completed accurately and returns were processed timely. Repeat finding: Finding is a repeat of finding 2022-002 in the immediately prior audit. Effect: Inaccurate calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed accurately and correctly to ensure that amounts earned by students who withdraw from the College are calculated correctly to ensure timely processing of returns, if any. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2023-002 – Special Tests: Title IV Assistance Earned Federal Program – Federal Pell Grant Federal ALN – 84.063 Federal Award Number – P063P188097 Federal Award Year – September 30, 2023 Federal Agency – U.S. Department of Education Pass-through Entity – Not Applicable Significant Deficiency Criteria: Calculation of the amount of Title IV Assistance earned is required by Title 34 in which the percentage of earned Title IV funds must be calculated by determining the percentage of the Title IV grant that has been earned by the student and applying that percentage to the total amount of Title IV grant that was or could have been disbursed to the student for the payment period or periods as of withdrawal date. Institutions are responsible for accurately calculating this amount and processing the return timely, if any. Condition / context: Out of a sample of four students who withdrew during the audit period, the Title IV worksheet was not completed correctly for two students that required a return of funds. Additionally, there was a delay in return of Title IV funds for both students that exceeded the maximum time allowed of 45 days after the date the institution determined that the student withdrew. The sample was not a statistically valid sample but was determined using Chapter 11 – Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify that the Title IV worksheet was completed accurately and returns were processed timely. Repeat finding: Finding is a repeat of finding 2022-002 in the immediately prior audit. Effect: Inaccurate calculation of the Title IV funds to be returned to a student can impact the student's financial wellbeing, ability to make timely financial and strategic decisions, and ability to enroll in the Title IV program in future periods. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that the Title IV worksheet is completed accurately and correctly to ensure that amounts earned by students who withdraw from the College are calculated correctly to ensure timely processing of returns, if any. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Return of Title IV funds calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand calculation and timing of returns. It should also be noted that in the current award year, CMN has moved to a model where attendance taking is not required, so staff is working with faculty and students to ensure timely notification of withdrawal and reviewing final grades at the end of the term in order to ensure all students needing a R2T4 calculation have one performed.
2022-002
FAC accepted this audit on April 16, 2023 — management decision was due October 16, 2023.
2021-001
FAC accepted this audit on February 15, 2022 — management decision was due August 15, 2022.
Finding: Item 2021-001 ? Special Tests: Enrollment Reporting Federal Program ? Federal Pell Grant ALN Number ?? 84.063 Federal Award Number ? P063P188097 Federal Award Year ? September 30, 2021 Federal Agency ? U.S. Department of Education Pass-through Entity ? Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, the College did not report the correct enrollment effective date for three students to the NSLDS. Additionally, two students did not have the correct enrollment status submitted to the NSLDS within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was accurately and timely submitted to the NSLDS. Repeat finding: Finding is a repeat of finding 2020-001 in the immediately prior audit. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure timeliness and accuracy. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Finding: Item 2021-001 ? Special Tests: Enrollment Reporting Federal Program ? Federal Pell Grant ALN Number ?? 84.063 Federal Award Number ? P063P188097 Federal Award Year ? September 30, 2021 Federal Agency ? U.S. Department of Education Pass-through Entity ? Not Applicable Significant Deficiency Criteria: In accordance with the Uniform Grant Guidance for student financial assistance programs, institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions are responsible for accurately reporting the following data to the Department of Education: OPEID number, enrollment effective date, enrollment status and certification date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition / context: Out of a sample of nine students receiving a Federal Pell Grant who withdrew or graduated during the audit period, the College did not report the correct enrollment effective date for three students to the NSLDS. Additionally, two students did not have the correct enrollment status submitted to the NSLDS within the specified timeframe. The sample was not a statistically valid sample but was determined using Chapter 11 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Procedures were not in place to verify the information was accurately and timely submitted to the NSLDS. Repeat finding: Finding is a repeat of finding 2020-001 in the immediately prior audit. Effect: Inaccurate or late enrollment reporting to NSLDS can impact a student's ability to receive a Federal Pell Grant by reporting them as enrolled after they have withdrawn or graduated, which could result in an over award of Pell Grant to the student. Recommendation: We recommend that the Financial Aid Coordinator institute a procedure that would ensure that all students who graduate or withdraw from the College are reported to the NSLDS correctly and within the timeframe specified and subsequently review the submission to ensure timeliness and accuracy. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
The College identified errors related to the effective dates reported to NSLDS through the National Student Clearinghouse, and has updated and corrected those errors. To address the issue of incorrect effective dates, the Registrar and Financial Aid office will work together to ensure that the effective date reported in our Student Information System correctly reflects the student?s last date of attendance. In order to continually address the issue of incorrect effective date, and the one status not reported to NSDLS in the required timeframe, the Financial Aid Coordinator and Registrar will work together to audit a number of students on a monthly basis. By double checking the monthly enrollment reports, issues such as the ones identified in this audit and the year prior audit may be addressed in a more effective manner.
2020-001
FAC accepted this audit on April 12, 2021 — management decision was due October 12, 2021.
FAC accepted this audit on March 11, 2020 — management decision was due September 11, 2020.
Item 2019-001 ? Eligibility Federal Program ? Federal Pell Grant CFDA Number ?? 84.063 Federal Award Number ? P063P188097 Federal Award Year ? September 30, 2019 Federal Agency ? U.S. Department of Education Pass-through Entity ? Not Applicable Criteria: Title 34 CFR Section 690.62 states the amount of a student's Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Additionally, Title 34 CFR Section 668.164 states that if an institution did not make a disbursement to an enrolled student for a payment period the student completed (for example, because of an administrative delay or because the student's ISIR was not available until a subsequent payment period), the institution may pay the student for all prior payment periods in the current award year or loan period for which the student was eligible. Condition / context: Out of a sample of 12 students receiving Federal Pell Grants, there were three students that were awarded the incorrect Pell Grant funds for the award year. Two students were eligible but not awarded Pell Grant funds totaling $4,062. The Pell Grant funds for one student was incorrectly calculated and over awarded $133. The sample was not a statistically valid sample but was determined using Chapter 11 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Two students attending the Fall payment period had their ISIRs selected for verification. Upon verification being completed in the Spring payment period and the students being determined eligible, no Pell Grant funds were retroactively disbursed for the Fall payment period to these students. There was a lack of review of verifications to ensure the eligible students were awarded the appropriate Pell Grant funds. Additionally, there was a lack of review to ensure one student's updated ISIR was utilized for determining the appropriately awarded Pell Grant funds. Effect: Three students didn't receive the proper amount of Pell Grant funds based on their eligibility. Questioned cost: $ - Recommendation: We recommend the College adjust the student records to reflect the accurate amount of Pell Grant funds and request the additional funds from the Department. The College should review those students' Pell Grant eligibility and ensure they are disbursed the correct funds in the proper pay periods when either ISIR verification is complete or an updated ISIR is submitted. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Show full finding ▾Hide full finding ▴Item 2019-001 ? Eligibility Federal Program ? Federal Pell Grant CFDA Number ?? 84.063 Federal Award Number ? P063P188097 Federal Award Year ? September 30, 2019 Federal Agency ? U.S. Department of Education Pass-through Entity ? Not Applicable Criteria: Title 34 CFR Section 690.62 states the amount of a student's Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Additionally, Title 34 CFR Section 668.164 states that if an institution did not make a disbursement to an enrolled student for a payment period the student completed (for example, because of an administrative delay or because the student's ISIR was not available until a subsequent payment period), the institution may pay the student for all prior payment periods in the current award year or loan period for which the student was eligible. Condition / context: Out of a sample of 12 students receiving Federal Pell Grants, there were three students that were awarded the incorrect Pell Grant funds for the award year. Two students were eligible but not awarded Pell Grant funds totaling $4,062. The Pell Grant funds for one student was incorrectly calculated and over awarded $133. The sample was not a statistically valid sample but was determined using Chapter 11 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Audit and Accounting Guide for Government Auditing Standards and Single Audits. Cause: Two students attending the Fall payment period had their ISIRs selected for verification. Upon verification being completed in the Spring payment period and the students being determined eligible, no Pell Grant funds were retroactively disbursed for the Fall payment period to these students. There was a lack of review of verifications to ensure the eligible students were awarded the appropriate Pell Grant funds. Additionally, there was a lack of review to ensure one student's updated ISIR was utilized for determining the appropriately awarded Pell Grant funds. Effect: Three students didn't receive the proper amount of Pell Grant funds based on their eligibility. Questioned cost: $ - Recommendation: We recommend the College adjust the student records to reflect the accurate amount of Pell Grant funds and request the additional funds from the Department. The College should review those students' Pell Grant eligibility and ensure they are disbursed the correct funds in the proper pay periods when either ISIR verification is complete or an updated ISIR is submitted. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.
Summary: Title 34 CFR Section 690.62 states the amount of a student's Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Additionally, Title 34 CFR Section 668.164 states that if an institution did not make a disbursement to an enrolled student for a payment period the student completed (for example, because of an administrative delay or because the student's ISIR was not available until a subsequent payment period), the institution may pay the student for all prior payment periods in the current award year or loan period for which the student was eligible. Out of a sample of 12 students receiving Federal Pell Grants, there were three students that were awarded the incorrect Pell Grant funds for the award year. Two students were eligible but not awarded Pell Grant funds totaling $4,062. The Pell Grant funds for one student was incorrectly calculated and over awarded $133. Corrective Action Plan (CAP): The College identified errors related to the retroactive payments and payment calculations and has corrected each error within Campus Nexus Student, the College's software product used in maintaining student information. The two students identified as being eligible for Pell funds and not paid have been distributed the funds for which they were eligible, and the overpayment has been refunded through G5. In the case of the Pell overpayment, the Financial Aid Coordinator has engaged with Campus Nexus Student to ensure the student EFC Calculations are performed on correct ISIR transactions. Federal Pell Payment Schedules created by the Department of Education are also now consulted to ensure correct calculations are being made for Pell payments. Since the notification of this potential finding the Financial Aid Coordinator has attended the Federal Student Aid conference, participated in Fundamentals of Federal Student Aid online training, joined in training webinars available through NASFAA, and is currently enrolled in an Internal Controls webinar. Although the instances above occurred during a previous employees tenure, the ability of the FA office to understand and implement Federal regulations within the Title IV program are foundational skills. We are committed to ensuring compliance in all areas of Federal Student Aid so that we can best serve our students in their higher education pursuits.
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