EIN: 370661227
UEI: GSA_MIGRATION
Audited by: SIKICH LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 22, 2022. 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 March 22, 2023 (1262 days ago).
What is a management decision? →The College did not timely and accurately complete refund calculations in the Fall and the Spring semesters. The College did not complete refund calculations timely for 3 out of 60 withdrawals (5%). In review of the Fall 2020 calculations the number of days in the break were not calculated correctly, resulting in the incorrect days in all Fall 2020 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 13 out of the population of 41 (31.7%) Fall withdrawal calculations. In review of the Spring 2021 calculations the College used the incorrect start and end dates, resulting in the incorrect days in all Spring 2021 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 17 out of the population of 19 (89.5%) of Spring withdrawal calculations. The College did not complete Title IV funds calculations for no passing grade withdrawal students for 4 out of 11 students tested (36.4%). We consider these conditions to be a material weakness to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $14,575. Effect: The College did not use the correct total days in their Return of Title IV calculation for both fall and spring semesters, which has the potential to result in incorrect aid to be kept or refunded for withdrawal students. Further the College did not timely complete Return of Title IV calculations for official and unofficial withdrawals. Recommendation: We recommend the College continually educate themselves on the Return of Title IV calculations. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria: 2020-2021 Federal Student Aid Handbook, Volume 3, Chapter 1, ?The number of weeks of instructional time is based on the period that generally begins on the first day of classes in the academic year and ends on the last day of classes or the last day of examinations, whichever is later.? 2020-2021 Federal Student Aid Handbook, Volume 5, Chapter 2, states ?Determine the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break. The last day of the scheduled break is the day before the next class is held. Where classes end on a Friday and do not resume until Monday following a one-week break, both weekends (four days) and the five weekdays would be excluded from the R2T4 calculation, for a total of nine days.? 34 CFR 668.22 (a)(1) states ?When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.? 34 CFR 668.22 (e)(2) states, ?The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or?? 34 CFR 668.22(j) notes, ?(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in ? 668.173(b).? See Schedule of Findings and Questioned Costs for chart/table. Condition: The College did not timely and accurately complete refund calculations in the Fall and the Spring semesters. The College did not complete refund calculations timely for 3 out of 60 withdrawals (5%). In review of the Fall 2020 calculations the number of days in the break were not calculated correctly, resulting in the incorrect days in all Fall 2020 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 13 out of the population of 41 (31.7%) Fall withdrawal calculations. In review of the Spring 2021 calculations the College used the incorrect start and end dates, resulting in the incorrect days in all Spring 2021 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 17 out of the population of 19 (89.5%) of Spring withdrawal calculations. The College did not complete Title IV funds calculations for no passing grade withdrawal students for 4 out of 11 students tested (36.4%). We consider these conditions to be a material weakness to the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $14,575. Effect: The College did not use the correct total days in their Return of Title IV calculation for both fall and spring semesters, which has the potential to result in incorrect aid to be kept or refunded for withdrawal students. Further the College did not timely complete Return of Title IV calculations for official and unofficial withdrawals. Recommendation: We recommend the College continually educate themselves on the Return of Title IV calculations. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: The College did not timely and accurately complete refund calculations in the Fall and the Spring semesters. The College did not complete refund calculations timely for 3 out of 60 withdrawals (5%). In review of the Fall 2020 calculations the number of days in the break were not calculated correctly, resulting in the incorrect days in all Fall 2020 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 13 out of the population of 41 (31.7%) Fall withdrawal calculations. In review of the Spring 2021 calculations the College used the incorrect start and end dates, resulting in the incorrect days in all Spring 2021 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 17 out of the population of 19 (89.5%) of Spring withdrawal calculations. The College did not complete Title IV funds calculations for no passing grade withdrawal students for 4 out of 11 students tested (36.4%). We consider these conditions to be a material weakness of the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: The Lincoln College financial aid department recalculated all R2T4 calculations for the impacted semesters. Our auditors at Sikich reviewed all of the recalculations. The resulting corrections were processed to all affected students. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid. Implementation Date for Corrective Action Plan: March 31, 2022
In our testing, we noted the College did not meet two out of the three Gramm-Leach-Bliley Act (GLBA) requirements. The College did not complete a risk assessment and did not assess safeguards for each risk. We consider this condition to be an instance of non-compliance of the Special Tests and Provisions compliance requirement and is not a repeated finding. Questioned Costs: N/A Cause and Effect: The College did not complete the GLBA requirements to protect Federal Student Aid applicant information. Recommendation: We recommend the College implement all requirements for GLBA Safeguards Rule. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria: 16 CFR 314.4 (a) ?In order to develop, implement, and maintain your information security program, you shall: (a) Designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. The Qualified individual may be employed by you, an affiliate, or a service provider. (b) Base your information security program on a risk assessment that identifies reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks. (c) Design and implement safeguards to control the risks you identify through risk assessment.? Condition: In our testing, we noted the College did not meet two out of the three Gramm-Leach-Bliley Act (GLBA) requirements. The College did not complete a risk assessment and did not assess safeguards for each risk. We consider this condition to be an instance of non-compliance of the Special Tests and Provisions compliance requirement and is not a repeated finding. Questioned Costs: N/A Cause and Effect: The College did not complete the GLBA requirements to protect Federal Student Aid applicant information. Recommendation: We recommend the College implement all requirements for GLBA Safeguards Rule. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: In our testing, we noted the College did not meet two out of the three Gramm-Leach-Bliley Act (GLBA) requirements. The College did not complete a risk assessment and did not assess safeguards for each risk. We consider this condition to be an instance of non-compliance of the Special Tests and Provisions compliance requirement and is not a repeated finding. Corrective Action Plan: We have partnered with a cybersecurity provider to enable a 24/7 endpoint detection and response platform for the College. This partnership will also allow us to more effectively conduct assessments to identify threats and vulnerabilities that will help us generate a practical view of our risk with confidence. The assessment will also include recommendations to deploy specific security controls, including recommendations related to employee training and management, information systems, and detecting, preventing and responding to attacks, intrusions, or other systems failures. Responsible Person for Corrective Action Plan: Brian Peacher, Director of Information Technology and Career Services. Implementation Date for Corrective Action Plan: Our 24/7 endpoint detection and response platform for the College is in place and operational. Our risk assessment is targeted to be completed by the end of the 3rd Quarter 2022.
FAC accepted this audit on March 28, 2021 — management decision was due September 28, 2021.
The College did not report current enrollment status changes for 2 out of 20 students (10%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2019-002. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The College has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans. Recommendation: We recommend the College continually educate themselves on compliance requirements regarding enrollment reporting and implement controls to help timely and accurately report enrollment statuses. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.? 34 CFR 685.309(b)(1-2) which states a school shall ?upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student?" Condition: The College did not report current enrollment status changes for 2 out of 20 students (10%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2019-002. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The College has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans. Recommendation: We recommend the College continually educate themselves on compliance requirements regarding enrollment reporting and implement controls to help timely and accurately report enrollment statuses. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: The College did not report current enrollment status changes for 2 out of 20 students (10%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2019-002. Statistical sampling was not used in making sample selections. Corrective Action Plan: As it regards the failure of the College to report current enrollment status changes pertaining to a subset of the population, the effected records appear to be attaching to a FICE and Branch code combination formerly used by the College (001709 80, formerly used by the Normal, Illinois campus of the College). A helpdesk ticket has been filed with the College?s IT department seeking assistance in locating the table associating the impacted ID numbers with the errant Branch code. In the meantime, and now that the error has been identified, the errant Branch code is being editing by hand in the NSC Student Data Collection table prior to each enrollment submission such that the `80? Branch code is replaced by the `00? code. Responsible Person for Corrective Action Plan: Nate McCoy, Director of Institutional Records and Research Implementation Date for Corrective Action Plan: December 31, 2020
2019-002
In our testing of forty students, the College was unable to provide documentation of one student (2.5%) completing exit counseling. We consider this condition to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2019-006. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College was unable to provide documentation that exit counseling was completed in accordance with Title IV requirements. Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Criteria: 34 CFR 685.304 (b) (1) ?A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school.? Condition: In our testing of forty students, the College was unable to provide documentation of one student (2.5%) completing exit counseling. We consider this condition to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2019-006. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College was unable to provide documentation that exit counseling was completed in accordance with Title IV requirements. Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: In our testing of forty students, the College was unable to provide documentation of one student (2.5%) completing exit counseling. We consider this condition to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2019-006. Statistical sampling was not used in making sample selections. Corrective Action Plan: This unique situation involved a student who was finishing the Fall semester with one class and, therefore, dropped below half-time enrollment status. The College did not provide exit counseling since the student was going to continue on in the Master?s program. The College learned the student must be provided exit counseling unless the student begins a new program within 30 days. Procedures are now in place whereby exit counseling is deployed anytime a student either drops below halftime or leaves the school for any reason. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid Implementation Date for Corrective Action Plan: December 15, 2020
2019-006
FAC accepted this audit on January 12, 2020 — management decision was due July 12, 2020.
The College did not complete monthly reconciliations for Direct Loan funds in accordance with 34 CFR 685. We consider this condition to be a material weakness of internal control over compliance relating to the Special Tests and Provisions? compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2018-002. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College did not implement procedures in order to complete monthly reconciliations for Direct Loan funds. Recommendation: We recommend the College implement procedures in order to complete monthly reconciliations for Direct Loan funds. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-001 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Criteria: 34 CFR 685.300 (b)(5) states ?On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary;? Condition: The College did not complete monthly reconciliations for Direct Loan funds in accordance with 34 CFR 685. We consider this condition to be a material weakness of internal control over compliance relating to the Special Tests and Provisions? compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2018-002. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College did not implement procedures in order to complete monthly reconciliations for Direct Loan funds. Recommendation: We recommend the College implement procedures in order to complete monthly reconciliations for Direct Loan funds. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2019-001 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Condition: The College did not complete monthly reconciliations for Direct Loan funds in accordance with 34 CFR 685. We consider this condition to be a material weakness of internal control over compliance relating to the Special Tests and Provisions? compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2018-002. Statistical sampling was not used in making sample selections. Corrective Action Plan: Management has developed a process and spreadsheet that aids in reconciling disbursements between the College?s general ledger and Powerfaids systems, COD, and the G5 drawdowns. Management continues to refine the process which includes utilizing best practices shared from other higher education institutions. Management?s reconciliation process is completed on a monthly basis. This reconciliation process has been shared with the College?s independent audit firm and the audit firm has indicated the process appears to meet the federal program requirements. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid Implementation Date for Corrective Action Plan: August 31, 2019
2018-002
The College did not report graduate status changes within 60 days for 1 out of 20 students tested (5%). The College did not report current enrollment status changes for 1 out of 20 students (5%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2018-003. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The College has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans. Recommendation: We recommend the College continually educate themselves on compliance requirements regarding enrollment reporting and implement controls to help timely and accurately report enrollment statuses. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-002 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit "in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.? 34 CFR 685.309(b)(1-2) which states a school shall ?upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student?" Condition: The College did not report graduate status changes within 60 days for 1 out of 20 students tested (5%). The College did not report current enrollment status changes for 1 out of 20 students (5%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2018-003. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The College has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans. Recommendation: We recommend the College continually educate themselves on compliance requirements regarding enrollment reporting and implement controls to help timely and accurately report enrollment statuses. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2019-002 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Condition: The College did not report graduate status changes within 60 days for 1 out of 20 students tested (5%). The College did not report current enrollment status changes for 1 out of 20 students (5%). We consider these conditions to be an instance of non-compliance to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior finding 2018-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: The Director of Institutional Research and Records views these findings as severable and has developed a corrective action plan accordingly. A. Regarding the failure to report graduate status change finding, the instance in question involved a student who interrupted his studies after applying for graduation, stepped out for one year, and then returned to the College to complete his requirements. An overreliance on paper-based processes led to the Registrar?s Office failing to confer the student?s degree upon completion of his second period of attendance, and said conferral, once corrected, was back-dated to reflect the date on which requirements were met. The corrective action taken to ensure such circumstances do not reoccur has consisted of enacting new policy regarding degree conferral. In cases meeting similar circumstances, the Registrar?s Office will now enter an individual transcript note indicating the date on which requirements were met but defining the conferral date as being equivalent to the official end date of the most recent sub-term. The student?s change in status will then be manually updated via National Student Clearinghouse (NSC) once the College?s records reflect the conferral. B. Regarding the failure to report current enrollment status changes finding, the case in question involved a student whose record was not retrieved and submitted to NSC via the Student Information System?s NSC reporting query. To address the College?s corrective action, an internal audit is being conducted on the query itself in order to identify the reason(s) for the failed retrieval. Should that audit find that the record was not retrieved due to inaccurate parameters, the query will be reconstructed to ensure compliance. Should the audit find that the query is valid and the student?s record contained data errors causing retrieval to fail, an additional data quality check query will be constructed, centering on the errant field(s) for all enrolled students, and added to the current monthly cycle of routine quality checks. Responsible Person for Corrective Action Plan: Nate McCoy, Director of Institutional Records and Research Implementation Date for Corrective Action Plan: A. Corrective action has already been taken in regards to item A above. Policy and procedural changes were effective August 31, 2019. B. Corrective action pertaining to item B is ongoing and regardless of specific action taken shall be completed no later than March 31, 2020.
2018-003
The College did not report actual loan disbursement dates to Common Origination and Disbursement (COD) agency for 5 out of 40 student sample (12.5%). We consider this Single Audit Finding to be a significant deficiency of internal control over compliance relating to Eligibility compliance requirements and is a repeat finding shown in Section IV of this report as prior finding 2018-004. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College had 5 instances of incorrect dates being reported to COD. All instances were due to manual adjustments being awarded to the student and the last disbursement date was not updated when reported to COD. Recommendation: We recommend the College implement procedures in order to report accurate disbursement dates for Direct Loans to the COD System. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-003 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Criteria: 34 CFR 668.164 (a)(1) states ?A disbursement of title IV, HEA program funds occurs on the date that the institution credits the student?s ledger account or pays the student or parent directly with ? (i) Funds received from the Secretary; or (ii) Institutional funds used in advance of receiving title IV, HEA program funds.? Condition: The College did not report actual loan disbursement dates to Common Origination and Disbursement (COD) agency for 5 out of 40 student sample (12.5%). We consider this Single Audit Finding to be a significant deficiency of internal control over compliance relating to Eligibility compliance requirements and is a repeat finding shown in Section IV of this report as prior finding 2018-004. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College had 5 instances of incorrect dates being reported to COD. All instances were due to manual adjustments being awarded to the student and the last disbursement date was not updated when reported to COD. Recommendation: We recommend the College implement procedures in order to report accurate disbursement dates for Direct Loans to the COD System. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2019-003 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Condition: The College did not report actual loan disbursement dates to Common Origination and Disbursement (COD) agency for 5 out of 40 student sample (12.5%). We consider this Single Audit Finding to be a significant deficiency of internal control over compliance relating to Eligibility compliance requirements and is a repeat finding shown in Section IV of this report as prior finding 2018-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: In this situation, students had increased their loan amounts after their original loan amounts had been disbursed. In these instances, Financial Aid Office personnel added the additional loan amount to the original loan amount not realizing the date would not change in COD. Upon consultation with COD, Financial Aid Office personnel learned the need to create an additional loan in the College?s Powerfaids system as a second disbursement so that both disbursement dates match the true disbursement dates in the College?s records, COD, and Powerfaids. This new procedure was implemented beginning with the Fall 2019 semester. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid Implementation Date for Corrective Action Plan: August 31, 2019
2018-004
Title IV funds not properly awarded and disbursed for five of forty (12.5%) students tested. We consider these conditions to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $10,527 Cause and Effect: Without proper review of eligibility for aid, students received an incorrect amount of Title IV aid. Recommendation: We recommend the College implement an additional level of review over financial aid packaging. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-004 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Criteria: 34 CFR 685.201 (a) (2) states ?If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.? 34 CFR 690.62 (A) notes ?The amount of a student?s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year.? Condition: Title IV funds not properly awarded and disbursed for five of forty (12.5%) students tested. We consider these conditions to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $10,527 Cause and Effect: Without proper review of eligibility for aid, students received an incorrect amount of Title IV aid. Recommendation: We recommend the College implement an additional level of review over financial aid packaging. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2019-004 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Condition: Title IV funds not properly awarded and disbursed for five of forty (12.5%) students tested. Corrective Action Plan: Students are often packaged for the subsequent school year before they have completed the current school year. Certain students were packaged with an incorrect loan amount primarily due to either attaining or not attaining the required cumulative credit hours to qualify for a change in class standing. Financial Aid Office personnel have now developed a process that monitors and verifies student class standing thereby ensuring correct loan amounts. Financial Aid Office personnel notify effected students of loan amount changes and obtain updated signed financial aid award letters, as needed. This new procedure was implemented beginning with the Fall 2019 semester. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid Implementation Date for Corrective Action Plan: August 31, 2019
The College did not retain supporting documentation for Part VI. Program Summary for Award Year July 1, 2017 through June 30, 2018, Section A. Distribution of Program Recipients and Expenditures by Type of Student. In addition, the information in Part V. Federal Work Study (FWS) Program for Award Year July 1, 2017 through June 30, 2018, Section G. Information About FWS students Employed in Community Service Activities was incorrectly reported. We consider these conditions to be a significant deficiency of internal control over compliance relating to the Reporting compliance requirement. Questioned Costs: N/A Cause and Effect: The College experienced turnover in key management position, and some records and supporting documentation could not be located by the College. Recommendation: We recommend the College implement procedures in order to properly report and retain supporting documentation for the FISAP. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2019-005 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Criteria: 34 CFR 668.24 (e)(1)(i) states ?(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep- ?(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including ?income grid information? for three years after the end of the award year in which the FISAP is submitted.? Condition: The College did not retain supporting documentation for Part VI. Program Summary for Award Year July 1, 2017 through June 30, 2018, Section A. Distribution of Program Recipients and Expenditures by Type of Student. In addition, the information in Part V. Federal Work Study (FWS) Program for Award Year July 1, 2017 through June 30, 2018, Section G. Information About FWS students Employed in Community Service Activities was incorrectly reported. We consider these conditions to be a significant deficiency of internal control over compliance relating to the Reporting compliance requirement. Questioned Costs: N/A Cause and Effect: The College experienced turnover in key management position, and some records and supporting documentation could not be located by the College. Recommendation: We recommend the College implement procedures in order to properly report and retain supporting documentation for the FISAP. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2019-005 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Condition: The College did not retain supporting documentation for Part VI. Program Summary for Award Year July 1, 2017 through June 30, 2018, Section A. Distribution of Program Recipients and Expenditures by Type of Student. In addition, the information in Part V. Federal Work Study (FWS) Program for Award Year July 1, 2017 through June 30, 2018, Section G. Information About FWS students Employed in Community Service Activities was incorrectly reported. We consider these conditions to be a significant deficiency of internal control over compliance relating to the Reporting compliance requirement. Corrective Action Plan: All supporting documentation related to FISAP preparation is now filed together in a common file for easy access and long-term record retention. In completing the FISAP for the award year July 1, 2017 through June 30, 2018, Financial Aid Office personnel inadvertently overlooked the Community Service Activities reporting section. The Community Service Activities are reported correctly on the FISAP for the award year July 1, 2018 through June 30, 2019. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid Implementation Date for Corrective Action Plan: June 30, 2019
In our testing of forty students, the College was unable to provide documentation of one student (2.5%) completing exit counseling. We consider this condition to be an instance of non-compliance to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College was unable to provide documentation that exit counseling was completed in accordance with Title IV requirements. Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-006 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Criteria: 34 CFR 685.304 (b) (1) ?A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school.? Condition: In our testing of forty students, the College was unable to provide documentation of one student (2.5%) completing exit counseling. We consider this condition to be an instance of non-compliance to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College was unable to provide documentation that exit counseling was completed in accordance with Title IV requirements. Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2019-006 ? Student Financial Aid Cluster ? (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans, CFDA No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 ? Year Ended June 30, 2019 Condition: In our testing of forty students, the College was unable to provide documentation of one student (2.5%) completing exit counseling. We consider this condition to be an instance of non-compliance to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: This unique situation involved a student who had previously attended the College, had a break in his period of enrollment, and then re-enrolled in the College. During the student?s current period of enrollment, he did not obtain any federal loans. When the student withdrew from the College during his current period of enrollment, an exit counseling letter was not sent to him. It was later discovered the student had obtained federal loans during his previous period of enrollment. Procedures have now been implemented whereby an exit counseling letter is sent to all students who withdraw from the College regardless of whether they have or have not obtained federal loans. This new procedure was implemented beginning with Fall 2019 semester. Responsible Person for Corrective Action Plan: Sherry Schonauer, Director of Financial Aid Implementation Date for Corrective Action Plan: August 31, 2019
FAC accepted this audit on February 10, 2019 — management decision was due August 10, 2019.
GSA_MIGRATION
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2017-002
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2017-003
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2017-004
FAC accepted this audit on December 9, 2017 — management decision was due June 9, 2018.
GSA_MIGRATION
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GSA_MIGRATION
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GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 28, 2017 — management decision was due September 28, 2017.
GSA_MIGRATION
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