EIN: 363005527
UEI: N5E7UNMDT711
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 26, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 26, 2025 (364 days ago).
What is a management decision? →The Chicago School (the College) had one instance of excess cash for the Federal Direct Student Loan program. During our cash management testing, we identified the College had excess cash for the Direct Loan program ranging from $528,450 to $1,238,306 for the period from November 13, 2023 to December 18, 2023. For that period, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned with a seven-day period. Cause: College officials stated the excess cash resulted from the College’s practice of drawing a portion of funds to ensure timely disbursement of stipend payments to students while the reconciliation of awards was still in progress. While this approach aligns with the College’s commitment to promptly provide financial support, an administrative oversight occurred during the reconciliation process. Specifically, the College did not net out the prior drawdown for stipends when calculating subsequent fund requests. Effect: Excess cash is noncompliance with Federal regulations and could result in heightened monitoring by the U.S. Department of Education. Questioned Costs: None Context: For the period of November 13, 2023 to December 18, 2023, the College had excess cash in the amount ranging from $528,450 to $1,238,306. The College held excess cash for a period of 24 business days. Repeat Finding: No. Recommendation: We recommend the College strengthen internal controls around cash management to prevent or timely correct excess cash instances. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Show full finding ▾Hide full finding ▴Finding 2024-001: Excess Cash – Student Financial Aid Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $202,369,164 Questioned Costs: None Criteria: Uniform Grant Guidance (34 CFR 668.166) states the Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution (1) received those funds from the Secretary; or (2) deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from awards adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure excess cash is properly handled. Condition: The Chicago School (the College) had one instance of excess cash for the Federal Direct Student Loan program. During our cash management testing, we identified the College had excess cash for the Direct Loan program ranging from $528,450 to $1,238,306 for the period from November 13, 2023 to December 18, 2023. For that period, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned with a seven-day period. Cause: College officials stated the excess cash resulted from the College’s practice of drawing a portion of funds to ensure timely disbursement of stipend payments to students while the reconciliation of awards was still in progress. While this approach aligns with the College’s commitment to promptly provide financial support, an administrative oversight occurred during the reconciliation process. Specifically, the College did not net out the prior drawdown for stipends when calculating subsequent fund requests. Effect: Excess cash is noncompliance with Federal regulations and could result in heightened monitoring by the U.S. Department of Education. Questioned Costs: None Context: For the period of November 13, 2023 to December 18, 2023, the College had excess cash in the amount ranging from $528,450 to $1,238,306. The College held excess cash for a period of 24 business days. Repeat Finding: No. Recommendation: We recommend the College strengthen internal controls around cash management to prevent or timely correct excess cash instances. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024
FAC accepted this audit on February 29, 2024 — management decision was due August 29, 2024.
During testing of students selected for verification, for 1 out 14 students selected for testing, the College could not provide the supporting verification documents. Cause: The financial aid administrator that performed the verification left the College shortly after performing the verification and did not properly save and maintain th documents. Effect: The College is required to maintain documents identifying the required verification procedures were performed in accordance with Department guidelines. Noncompliance with federal guidelines could imapct future funding. Questioned Costs: None Context: For 1 out of 14 students selected for verification testing, verification documents could not be provided identifying the verification procedures were completed. Repeat Finding: No Recommendation: We recommend the College strengthen internal controls and ability of administrators to pull information saved by specific employees prior to departure. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Show full finding ▾Hide full finding ▴Finding 2023-001: Special Tests and Provisions – Lack of Maintaining Verification Documents Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2022 – May 31, 2023 Program Expenditures: $200,070,965 Criteria: Per 34 CFR 668.57, if an applicant is selected to verify information, an institution must obtain the specified documentation. Condition: During testing of students selected for verification, for 1 out 14 students selected for testing, the College could not provide the supporting verification documents. Cause: The financial aid administrator that performed the verification left the College shortly after performing the verification and did not properly save and maintain th documents. Effect: The College is required to maintain documents identifying the required verification procedures were performed in accordance with Department guidelines. Noncompliance with federal guidelines could imapct future funding. Questioned Costs: None Context: For 1 out of 14 students selected for verification testing, verification documents could not be provided identifying the verification procedures were completed. Repeat Finding: No Recommendation: We recommend the College strengthen internal controls and ability of administrators to pull information saved by specific employees prior to departure. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.
Corrective Action Plan – The Chicago School Identifying Number: 2023-001 Finding: Special Tests and Provisions- Lack of Maintaining Verification Documents Applicable Regulation: Per 34 CFR 668.57, if an applicant is selected to verify information, an institution must obtain the specified documentation. Finding: During testing of students selected for verification, for 1 out of 14 students selected for testing, the College could not provide the supporting verification documents. Summary: According to our records, after this student was selected by the Department of Education for verification, the student submitted the required verification worksheet (V4) on 8/22/22. The financial aid advisor that performed the verification left the College shortly after performing the verification and did not properly save and maintain the documents. On 8/25/23, staff reached out to the student via phone and email to retrieve a copy of the previously submitted V4 worksheet but did not receive a response. The advisor that originally verified the file is no longer employed by The Community Solution. Corrective Action Taken or Planned: On 7/1/23, the Financial Aid Training Department assumed the role and responsibilities of reviewing all financial aid files for accuracy. The department conducts reviews on a weekly basis with oversight provided by the Financial Aid Training Manager. As the result of each weekly audit, a report is compiled and provided to both financial aid leadership and staff. If there are any missing documents or errors found, these are tracked through to completion by the training department. Additionally, the Financial Aid team provides 1:1 training to staff if errors are uncovered during the weekly review. The error in question did not create any financial liabilities for the student or institution as the aid received was not need based. The institution informed RSM of this error and the corrective actions taken. Contact Person Lawrence McGhee, Associate Vice President of Financial Aid lawrencemcghee@tcsedsystem.edu Anticipated Completion Date July 1, 2023
FAC accepted this audit on December 1, 2021 — management decision was due June 1, 2022.
One student?s enrollment status change date was not properly reported. Cause: One student?s enrollment status change date was not properly reported. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, not reporting enrollment status changes within the required timeframe can impact an individual student?s loan deferment and repayment schedule. Questioned costs: None Context: One of 47 students tested from a population of 1,500 students with enrollment status changes was not reported in the required timeframe. Repeat finding: No Recommendation: The College should enhance their internal controls related to student enrollment status changes. The College should implement procedures to ensure the registrar?s office uploads the proper withdrawal dates and communicates with the student aid office so the student aid office can report the changes to the lender with the appropriate information. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Direct Student Loans Assistance Listing Number: 84,007, 84.033, 84.268 Award Year: June 1, 2020 ? May 31, 2021 Program Expenditures: $192,998,025 Questioned Costs: None Criteria: Per 34 CFR 682.605(c), a School is required to notify the lender and the Secretary of a student?s withdrawal date including the month, day and year of the withdrawal date. Condition: One student?s enrollment status change date was not properly reported. Cause: One student?s enrollment status change date was not properly reported. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, not reporting enrollment status changes within the required timeframe can impact an individual student?s loan deferment and repayment schedule. Questioned costs: None Context: One of 47 students tested from a population of 1,500 students with enrollment status changes was not reported in the required timeframe. Repeat finding: No Recommendation: The College should enhance their internal controls related to student enrollment status changes. The College should implement procedures to ensure the registrar?s office uploads the proper withdrawal dates and communicates with the student aid office so the student aid office can report the changes to the lender with the appropriate information. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Identifying Number: 2021-001 Finding: During performance of special tests and provisions, 1 out of 47 students tested for enrollment status changes had an improperly reported status change date. Per 34 CFR 682.605(c), a School is required to notify the lender and the Secretary, a student?s withdrawal date including the month, day and year of the withdrawal date. Corrective Action Taken or Planned: In July, 2020, the manual processing of NSLDS records for nursing students was eliminated as a result of the merger of the Dallas Nursing Institute and The Chicago School of Professional Psychology. All nursing student records are now processed through the National Clearinghouse in an automated fashion. These measures will help to ensure that students are accurately extracted with the correct dates and subsequently reported to the Clearinghouse in a timely manner. The person responsible for the completion of the corrective action plan is Tonya Henry Vice President of Student Finance, and can be reached at (312) 488.6057 or thenry@tcsedsystem.edu.
One student?s portion of unearned assistance was returned by the College. Cause: One student?s portion of unearned assistance was returned by the College. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, improperly returning funds on behalf of a student could lead to the student not being eligible to receive additional Title IV aid. Questioned costs: $912 Context: One of 40 students tested from a population of 734 students that required the review of a Return of Title IV calculation did not have the proper funds returned. Repeat finding: No Recommendation: The College should enhance their internal controls related to amounts returned for Title IV between the College and the students. The College should implement procedures to ensure the amounts returned are in agreement with the amounts calculated within the Return of Title IV calculation for each student. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2020 ? May 31, 2021 Program Expenditures: $191,332,678 Questioned Costs: $912 Criteria: Per 34 CFR 668.22(h)(i), the student must return assistance for which the student is responsible. Condition: One student?s portion of unearned assistance was returned by the College. Cause: One student?s portion of unearned assistance was returned by the College. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, improperly returning funds on behalf of a student could lead to the student not being eligible to receive additional Title IV aid. Questioned costs: $912 Context: One of 40 students tested from a population of 734 students that required the review of a Return of Title IV calculation did not have the proper funds returned. Repeat finding: No Recommendation: The College should enhance their internal controls related to amounts returned for Title IV between the College and the students. The College should implement procedures to ensure the amounts returned are in agreement with the amounts calculated within the Return of Title IV calculation for each student. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Identifying Number: 2021-002 Finding: During performance of special tests and provisions, 1 out of 40 students tested for proper Return of Title IV funds calculations had an improper amount returned. Per 34 CFR 668.22(h)(i), the student must return assistance for which the student is responsible. Corrective Action Taken or Planned: A refresher training will be conducted and documented with the Financial Aid Specialist team in October, 2021 to highlight the proper amounts that should be returned by the institution when a Return of Title IV funds calculation is performed. The person responsible for the completion of the corrective action plan is Tonya Henry Vice President of Student Finance, and can be reached at (312) 488.6057 or thenry@tcsedsystem.edu.
One student?s verification documents were not properly retained. Cause: One student?s verification documents were not properly retained by the College. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, improperly clearing verification flags could result in the student not being eligible to receive additional Title IV aid. Questioned costs: None Context: One of 21 students tested from a population of 205 students that flagged for the Verification Process did not have the proper verification documents. Repeat finding: No Recommendation: The College should enhance their internal controls related to their Verification tracking process between the College and the students. The College should implement procedures to ensure the verification documents are being properly retained. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.007, 84.063, 84.268 Award Year: June 1, 2020 ? May 31, 2021 Program Expenditures: $192,998,025 Questioned Costs: None Criteria: Per 34 CFR 668.53(c), an institution's must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the HEA to make changes to the applicant's cost of attendance or to the values of the data items required to calculate the EFC. Condition: One student?s verification documents were not properly retained. Cause: One student?s verification documents were not properly retained by the College. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, improperly clearing verification flags could result in the student not being eligible to receive additional Title IV aid. Questioned costs: None Context: One of 21 students tested from a population of 205 students that flagged for the Verification Process did not have the proper verification documents. Repeat finding: No Recommendation: The College should enhance their internal controls related to their Verification tracking process between the College and the students. The College should implement procedures to ensure the verification documents are being properly retained. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Identifying Number: 2021-003 Finding: During performance of special tests and provisions, 1 out of 21 students tested was flagged for Verification and did not have the proper verification documents. Per 34 CFR 668.53(c), an institution's must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the HEA to make changes to the applicant's cost of attendance or to the values of the data items required to calculate the EFC. Corrective Action Taken or Planned: A refresher training will be conducted and documented with the Financial Aid Advising team in November, 2021 to highlight the significance of reviewing the verification status of each award year of a student?s Institutional Student Information Record (ISIR) and ensuring the appropriate verification documents are collected, reviewed and assessed for financial aid eligibility. The person responsible for the completion of the corrective action plan is Tonya Henry Vice President of Student Finance, and can be reached at (312) 488.6057 or thenry@tcsedsystem.edu.
FAC accepted this audit on December 6, 2020 — management decision was due June 6, 2021.
One student?s enrollment status change was not properly reported within the required timeframe. Cause: One student?s enrollment status change was not reported timely. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, not reporting enrollment status changes within the required timeframe can impact an individual student?s loan deferment and repayment schedule. Questioned Costs: None Context: One of 45 students tested from a population of 1,263 students with enrollment status changes was not reported in the required timeframe. Repeat finding: No Recommendation: The College should enhance their internal controls related to student enrollment status changes. The College should implement procedures to ensure the registrar?s office uploads withdrawal dates timely and communicates with the student aid office so the student aid office can report the changes to the lender in a timely manner. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans CFDA Number: 84.268 Award Year: June 1, 2019 ? May 31, 2020 Program Expenditures: $179,510,153 Questioned Costs: None Criteria: Per 34 CFR 685.309(b)(2), a School is required to notify the lender within 30 days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. The School has 30 days to notify the lender if the next scheduled roster reporting date is within 30 days of the date of determination of a status change. Condition: One student?s enrollment status change was not properly reported within the required timeframe. Cause: One student?s enrollment status change was not reported timely. The College?s internal controls failed to detect the error. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, not reporting enrollment status changes within the required timeframe can impact an individual student?s loan deferment and repayment schedule. Questioned Costs: None Context: One of 45 students tested from a population of 1,263 students with enrollment status changes was not reported in the required timeframe. Repeat finding: No Recommendation: The College should enhance their internal controls related to student enrollment status changes. The College should implement procedures to ensure the registrar?s office uploads withdrawal dates timely and communicates with the student aid office so the student aid office can report the changes to the lender in a timely manner. Management?s response: Management agrees with this finding. Please see corrective action plan attached.
Identifying Number: 2020-001 Finding: During performance of eligibility testing, 1 out of 45 students tested for enrollment status changes was not reported in the required timeframe. Per 34 CFR 685.309(b)(2), a School is required to notify the lender within 30 days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. The School has 30 days to notify the lender if the next scheduled roster reporting date is within 30 days of the date of determination of a status change. Corrective Action Taken or Planned: Beginning in February, 2020, the Academic Records & Compliance team modified its procedures to include the review of a registered-not-active report prior to the monthly Clearinghouse report to identify any students who may have an active status without any registration. These measures will help ensure that students are accurately coded by status and subsequently reported to the Clearinghouse in a timely manner. The person responsible for the completion of the corrective action plan is Tonya Henry Vice President of Student Finance, and can be reached at (312) 488.6057 or thenry@tcsedsystem.edu.
FAC accepted this audit on November 1, 2018 — management decision was due May 1, 2019.
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