EIN: 370661491
UEI: UGX5THJHRW95
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2025 (327 days ago).
What is a management decision? →The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%). We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $1,500 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Subsidized Direct Loans. 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 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.” Condition: The College did not properly disburse Direct Subsidized loans for 2 out of 40 students (5%). We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $1,500 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Subsidized Direct Loans. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Identification and Review • Immediately review and recalculate the subsidized need for the affected students. (Completed) • Identify the sources of aid contributing to the excess amount and whether any adjustments can be made within the same academic year • Adjust the loan amounts as necessary and return any excess funds to the Department of Education. (Completed) • Review packaging procedures to pinpoint the cause of the discrepancy (e.g., late outside scholarships, system errors, or manual adjustments Student Award Adjustments • Reduce or cancel institutional or federal aid (such as loans, Federal Work-Study, or certain grants) in accordance with federal regulations and institutional policies • If the excess aid cannot be adjusted within the same academic year, follow federal guidelines to return any over awarded federal funds through the Common Origination and Disbursement (COD) system • Notify students of any changes to their financial aid package and provide guidance on alternative funding options if needed System Enhancements • Implement system-level edits and warnings in the financial aid software to flag over-awards before disbursement. • Schedule regular audits of loan disbursements to ensure ongoing compliance Policy and Procedure Update • Update the financial aid packaging policy to include stricter controls for verifying subsidized need calculations. • Implement a cross-check system for all financial aid components before loan disbursement • Require timely reporting of external scholarships and third-party payments to prevent adjustments after disbursement Monitoring and Compliance • Conduct training sessions for financial aid staff on loan eligibility calculations. • Conduct periodic reconciliation of student aid packages throughout the academic year to prevent over awards • Provide guidance on using the financial aid management system's tools to avoid over-awards Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 02/25/25
The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%). We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $0 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. 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 685.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) 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.” Condition: The College did not properly disburse Direct Unsubsidized Loans for 3 out of 40 students (7.5%). We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $0 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Identification and Review • Identify all students who received incorrect loan amounts (Completed) • Make appropriate adjustments to loan disbursements (Completed) • Notify affected students and provide guidance on next steps (Completed) Policy and Procedure Enhancements • Develop clear, written procedures for verifying loan amounts prior to disbursement • Implement a two-step verification process for loan packaging System Controls • Collaborate with IT to implement automated system checks to flag discrepancies • Enhance reporting tools for regular audits and monitoring Staff Training • Conduct comprehensive training sessions for financial aid staff on federal regulations regarding Direct Loans • Provide ongoing refresher courses and updates as federal policies change Monitoring Continuous Improvement • Establish a quarterly audit process to ensure compliance • Monitor loan discrepancies detected and correct as needed • Conduct regular audits to confirm compliance with federal loan regulations. • Collect feedback from staff on the effectiveness of training Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 03/03/25
One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $280 Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance. Recommendation: We recommend the College refund $280 and increase controls over student 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 ▴Criteria: A student’s total aid may not exceed the student’s financial need (Section 472, HEA). Condition: One of the forty student files (2.5%) we examined, we noted the student was awarded aid in excess of her cost of attendance budget. We consider this condition to be an instance of noncompliance to the Eligibility compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: $280 Cause and Effect: Without proper review of cost of attendance budgets students may receive funds in excess of their cost of attendance. Recommendation: We recommend the College refund $280 and increase controls over student aid packaging. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Identification and Review • Conduct an internal audit of all financial aid awards for the affected students to determine the extent of the overaward • Identify the sources of aid contributing to the excess amount and whether any adjustments can be made within the same academic year. • Review packaging procedures to pinpoint the cause of the discrepancy (e.g., late outside scholarships, system errors, or manual adjustments Student Award Adjustments • Reduce or cancel institutional or federal aid (such as loans, Federal Work-Study, or certain grants) in accordance with federal regulations and institutional policies. • Notify students of any changes to their financial aid package and provide guidance on alternative funding options if needed. Process and Policy Improvements • Implement a cross-check system for all financial aid components and strengthen internal controls to ensure total aid does not exceed COA before disbursement • Implement additional system checks and alerts in the financial aid management system to flag overawards automatically. • Require timely reporting of external scholarships and third-party payments to prevent adjustments after disbursement Monitoring and Compliance • Conduct periodic reconciliation of student aid packages throughout the academic year to prevent overawards • Train financial aid staff on COA regulations and best practices for awarding aid Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 2/25/25
The College did not report enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans. Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting. 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 enrollment status changes for 9 out of 40 students (23%). We consider this condition to be a significant deficiency for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: Since the College did not timely and accurately submit enrollment status information, there could be a delay to the start of the repayment period for students receiving direct loans. Recommendation: We recommend that the College closely monitor enrollment reporting and implement additional controls to assure timely and accurate reporting. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Identification and Review • Conduct a comprehensive audit of enrollment records to identify instances of inaccurate or delayed reporting • Verify the accuracy of enrollment statuses (e.g., full-time, half-time, withdrawn, graduated) for all affected students • Determine the root cause of reporting delays or errors, whether due to system malfunctions, manual processing errors, or lack of oversight Corrective Actions • Submit corrected enrollment data to NSLDS for all affected students using our National Student Clearinghouse. • Ensure that all errors identified during the audit are addressed, and follow up to confirm the corrections are reflected in NSLDS. • Notify any impacted students of any changes in their enrollment status and provide necessary support if their loan repayment terms are affected. Process and Policy Improvements • Develop and implement clear policies to ensure accurate and timely submission of enrollment data within the required 30-day reporting window or in accordance with scheduled reporting intervals. • Automate the enrollment reporting process where possible to minimize manual data entry errors. • Establish cross-departmental communication protocols to ensure timely updates on student withdrawals, graduations, and status changes. • Create detailed documentation of reporting procedures for staff training and compliance purposes. Monitoring and Compliance • Implement regular reconciliation checks between our student information system (SIS) and NSLDS to ensure data accuracy • Conduct periodic internal audits to identify discrepancies before external audits occur • Designate staff to oversee enrollment reporting and ensure adherence to federal regulations. Staff Training • Provide comprehensive training for staff responsible for enrollment reporting on NSLDS requirements, deadlines, and best practices • Offer training sessions as regulations change or system updates occur. Reporting and Documentation • Maintain records of all corrected data submissions, audit results, and communications with NSLDS • Document procedural changes and staff training efforts Responsible Person for Correction Action Plan: Dianna Ruyle, Director of Records, Registration and Advising Implementation Date for Corrective Action Plan: Immediately and ongoing
The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency 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: $4,126 Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education. Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance. 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 668.22 (j) (2) states “For an institution that is not required to take attendance, an institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the - (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e) (5) of this section; (ii) academic year in which the student withdrew; or (iii) Educational program from which the student withdrew.” Condition: The College did not complete Title IV funds calculations for no passing grade withdrawal students for 1 out of 3 students tested (33.3%). We consider this condition to be a significant deficiency 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: $4,126 Cause and Effect: The College did not timely complete Return of Title IV calculations for an unofficial withdrawal. The result is Title IV funds that were not returned to the Department of Education. Recommendation: We recommend the College complete a Return to Title IV refund calculation for the one student in question and increase controls over monitoring attendance. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Identification and Review • Conduct an internal audit to identify all students who failed all courses and determine the last date of attendance for each. • Review institutional records (For example, faculty attendance records, Learning Management or participation records) to establish when students stopped engaging academically • Verify whether R2T4 calculations should have been performed Corrective Actions • Process R2T4 calculations for affected students based on their last date of attendance • Return any unearned Title IV funds • Update students file to reflect accurate withdrawal dates and notify them of any financial obligations resulting from the adjustment • If students are still enrolled in future terms, ensure they understand satisfactory academic progress (SAP) implications Process and Policy Improvements • Implement an early alert system to identify students who cease attendance before the end of the term. • Strengthen collaboration between academic departments, the registrar, and the financial aid office to improve withdrawal tracking • Run monthly withdrawal reports to see when students earn all failing grades. Monitoring and Compliance • Conduct regular audits to ensure compliance with R2T4 regulations and timely student withdrawals • Provide staff training on withdrawal procedures and the importance of accurately tracking last dates of attendance. • Establish a set time to review withdrawal policies and ensure adherence to federal regulations. Reporting and Documentation • Maintain detailed records of all identified cases, R2T4 calculations, and funds returned. • Document all policy and procedural updates made to prevent recurrence. • If required, submit a report to the U.S. Department of Education outlining corrective actions taken. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: 2/25/25
During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections. Questioned Costs: $306 Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Show full finding ▾Hide full finding ▴Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.” Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.” Volume 6, Chapter 2 of the 2023-2024 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid.” Condition: During our testing of thirty-seven individuals receiving federal work study, we noted ten individuals (27%) working during scheduled class hours. We also noted one of thirty-seven individuals (3%) where the individual’s hours recorded per the timesheet were less than the hours actually paid. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections. Questioned Costs: $306 Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours or for hours not actually worked.
Identification and Review • Students clocked in during scheduled class times. Blackburn did not initially educate nor send reminders to students and faculty about students not being able to clock in during class times. • During the 2023-2024 fiscal year, there was a transition in the Dean of Work role. There was not as much oversight of student payroll reports Corrective Actions • The Work Office and Provost Office has increased communication and education about students not being able to work during scheduled class times. Reminders have also been sent out. • The Work Office now has a Dean of Work who is educated about how to run student payroll. Process and Policy Improvements • Starting in the Fall 2024 semester, the Work Office and Provost Office increased awareness and communication regarding students not being allowed to work during scheduled class times. • Student Communication- Student managers communicated with student employees at monthly department meetings and through electronic communication that students are not allowed to clock in during scheduled class times. The exception is when their class is cancelled, and students must send the class cancellation notice (email from Professor or screenshot of Learning Management System announcement) to the Work Office before clocking in during the cancelled class time. Once the cancelled claim information is received, it is added to a spreadsheet maintained jointly by the Provost and Work Office. Professor Communication- The Provost sent an electronic communication to all professors notifying them they must communicate with the Provost and Work Office when they cancel a class. Once the cancelled class information is received, it is added to a spreadsheet maintained jointly by the Provost and Work Office. • Additionally, the Work Office reached out to our time tracking and payroll software vendor to identify a solution to limit students' ability to clock in during scheduled class times. Monitoring and Compliance • The Work Office and Provost Office will dedicate time to educate and remind students and faculty that students are not allowed to work during scheduled class time, and how to report a cancelled class. • The Work Office will dedicate time to double check the student payroll reports before sending them to Human Resources. • The Dean of Work will ensure students are educated in department meetings and through electronic communication that they are not allowed to clock in to work during scheduled class times, and how to report a cancelled class. • The Dean of Work will coordinate with the Provost Office to ensure faculty are educated about students not being able to clock in during scheduled class times, and how to report a class cancellation. • The Dean of Work will randomly select 10 students each payroll to ensure they are not clocking in during their scheduled class times. • The Dean of Work will also ensure that the student payroll is double checked before sending to Human Resources. Reporting and Documentation • Fall 2024 o Student managers educated students during their first department meeting And students also received electronic communication that they could not work during a scheduled class time, and informed them how to report a cancelled class. o The Provost Office sent electronic communication to faculty on the importance of reporting a class cancellation. • Spring 2025 o Student managers educated students during their first department meeting and students also received electronic communication that they could not work during a scheduled class time, and informed them how to report a cancelled class. o The Provost Office sent electronic communication to faculty on the importance of reporting a class cancellation. o The Work Office is facilitating monthly Supervisor trainings. In the February training, supervisors were informed verbally and in writing about students not being able to work during scheduled class times, and what documentation is needed when a class is cancelled. • Fall 2025 o The Work Office will facilitate a Supervisor training before the academic year begins. In the training, we will review policies and procedures with one of them being students not being able to clock in during scheduled class times. Responsible Person for Correction Action Plan: Leslie Johnson, Dean of Work Implementation Date for Corrective Action Plan: 09/03/24
2023-003
The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding. Questioned Costs: $328 Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained. Recommendation: We recommend the College return $328 to the Department. 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 668.163 (c)(3) notes, “An Institution may keep the initial $500 in interest it earns during the award year on the other title IV, HEA program funds it maintains in accordance with paragraph (c)(1) of this section. No later than 30 days after the end of that award year, the institution must remit to the Department of Health and Human Services, Payment Management System, Rockville, MD 20852, any interest over $500.” Condition: The College retained interest earnings in excess of $500 in their federal bank account during fiscal year 2024. We consider this condition to be an instance of noncompliance relating to the Cash Management compliance requirement and is not a repeated finding. Questioned Costs: $328 Cause and Effect: Without proper review of their federal bank account interest greater than $500 may be retained. Recommendation: We recommend the College return $328 to the Department. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
FY24 interest in the amount of$331.01 was returned to USDHHS PS Program Suppmi Center on 1/30/2025. We are keeping a smaller balance in the Federal Funds bank account to lessen the amount of interest earned on the account. Any amount over $500 at the end of the fiscal year will be returned through the same process as prior years. Responsible Person for Correction Action Plan: Deana Rogers, Vice President of Administration & Finance Implementation Date/or Corrective Action Plan: 01/30/25
FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.
During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $154 Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours. 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 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.” Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $154 Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
The largest issue regarding student working when they are in class is communication. Faculty are supposed to alert the work office when they are cancelling class. However, they are only alerting the Provost about cancelling classes and they are keeping a calendar of cancelled classes. We will continue to remind faculty that they must let the Work Office know directly when they cancel class. All managers have been informed that their workers cannot work during a class period unless the professor has emailed the work office. We are looking at new payroll vendors who may be able develop a system for student schedules and the payroll system to help integrate data so that we can access class schedules within the Payroll system and blackout periods where they cannot work.
The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch. Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. 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 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, 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 form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch. Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Our Correction Plan will be to check monthly that loan disbursements correctly match with COD. While progress was definitely made from the prior year, it is important that every student disbursement is correctly shown by the Business Office.
2022-004
The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 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 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. 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 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).” An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22). Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 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 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Although we checked and double checked the information as shown in COD under the R2T4 section, there still appears to be an issue with regards to COD correctly showing Vacation time in COD. Going forward, we are actually printing out the R2T4's to ensure that the correct number of days are listed on the R2T4 sheet and maintaining hard copies in addition to saving online.
2022-005
The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement. Questioned Costs: N/A Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year. Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation. 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 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 accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement. Questioned Costs: N/A Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year. Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
The information that we listed initially only included the Work Study portion. However, the number of students was correct. Going forward, we will ensure that both portions are listed correctly on the FISAP.
The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs. Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education. 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: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Base your information security program on a risk assessment that identifies reasonably 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 (16 CFR 314.4(b)). Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs. Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
We’ve updated processes to include documentation of risks associated with protecting customer data. Risk assessment documents and methodologies will be reviewed and updated in consultation with the Vice-President of Administration & Finance and the Director of Technology Services.
Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds. 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: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304). Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds. 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.
At the beginning of each semester, the Registrar will run a No Show report and share the report with the Financial Aid Office to show which students did not return for the current semester.
FAC accepted this audit on May 8, 2023 — management decision was due November 8, 2023.
Two of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. Further, we noted two of the 40 students (5%) were not properly awarded Pell. See Schedule of Findings and Questioned costs for chart/table. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2021-002. Statistical sampling was not used in making sample selections. Questioned Costs: $4,188. Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. 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 682.201 (a) (1-2) notes, ?(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) 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 states, ?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: Two of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. Further, we noted two of the 40 students (5%) were not properly awarded Pell. See Schedule of Findings and Questioned costs for chart/table. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2021-002. Statistical sampling was not used in making sample selections. Questioned Costs: $4,188. Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: Two of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. Further, we noted two of the 40 students (5%) were not properly awarded Pell. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office at Blackburn has evaluated and revised policies and procedures to ensure students receive the proper amount of Title IV Aid. Reconciling each month is necessary to ensure we catch any and all discrepancies that may occur. We will continue to utilize all available software to assist with packaging and that will allow all financial aid, including Title IV funds, to be reviewed frequently by both the Director of Financial Aid and the Assistant Director of Financial Aid. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: April 2023
2021-002
The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 23 of the 40 students in the sample (57.5%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2021-003. Statistical sampling was not used in making sample selections. Questioned Costs: N/A. Cause and Effect: The College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS. Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. 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 668.164 (a)(1) states ?Except as provided under paragraph (a)(2) of this section, 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 form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 23 of the 40 students in the sample (57.5%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2021-003. Statistical sampling was not used in making sample selections. Questioned Costs: N/A. Cause and Effect: The College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS. Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. 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 actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 23 of the 40 students in the sample (57.5%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2021-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office must emphasize the importance of accurate record-keeping in financial transactions. As a department we will continue to work closely with the Business office to ensure that every drawdown is properly documented and matches the corresponding dates and amounts. Additionally, we will continue to perform monthly reconciliations to ensure that any discrepancies are identified and addressed promptly. This process helps to minimize errors and maintain transparency in our overall financial aid operations. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Fall 2022
2021-003
The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2021 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 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 6 out of the population of 11 (54.5%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2021-004. Statistical sampling was not used in making sample selections. See Schedule of Findings and Questioned Costs for chart/table. Questioned Costs: $1,439. Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College. The result of not notifying the student of a post-withdrawal disbursement is the student is unaware of the additional loan amount. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. 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 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).? An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student?s account for outstanding charges (34 CFR 668.22). Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2021 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 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 6 out of the population of 11 (54.5%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2021-004. Statistical sampling was not used in making sample selections. See Schedule of Findings and Questioned Costs for chart/table. Questioned Costs: $1,439. Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College. The result of not notifying the student of a post-withdrawal disbursement is the student is unaware of the additional loan amount. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. 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. In review of the Fall 2021 calculations the number of days in the break were not calculated correctly, resulting in the incorrect days in all Fall 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 6 out of the population of 11 (54.5%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2021-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid staff at Blackburn Colleges understands that when calculating Return of Title IV funds, it is important to carefully review and accurately count the number of calendar days in the payment period. Currently, we review the College Academic Calendar for all vacations periods and ensure that any periods that are 5 or more days in length are added when setting up the School Calendar Profile in the R2T4 screen each academic year. This will help to make certain that all relevant dates are properly documented and that we are using the correct formula for calculating R2T4. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Fall 2022
2021-004
One out of eleven (9.1%) students selected for testing, was disbursed a post-withdrawal disbursement without a notification being sent to authorize the loan disbursement. This was a result of the withdrawal for this student being completed late. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. See Schedule of Findings and Questioned Costs for chart/table. Questioned Costs: $1,577. Effect: The result of not notifying the student of a post-withdrawal disbursement is the student is unaware of the additional loan amount. Recommendation: We recommend that the College increase controls over post-withdrawal disbursements. No payment is recommended as the loan amount was returned. 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: An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student?s account for outstanding charges (34 CFR 668.22). Condition: One out of eleven (9.1%) students selected for testing, was disbursed a post-withdrawal disbursement without a notification being sent to authorize the loan disbursement. This was a result of the withdrawal for this student being completed late. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. See Schedule of Findings and Questioned Costs for chart/table. Questioned Costs: $1,577. Effect: The result of not notifying the student of a post-withdrawal disbursement is the student is unaware of the additional loan amount. Recommendation: We recommend that the College increase controls over post-withdrawal disbursements. No payment is recommended as the loan amount was returned. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: One out of three (33.3%) students selected for testing in the Spring, was disbursed a post-withdrawal disbursement without a notification being sent to authorize the loan disbursement. This was a result of the withdrawal for this student being completed late. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office has increased controls over post-withdrawals disbursements in several ways: Establishing updated policies and procedures for disbursing funds after a student withdraws. The policy includes guidelines for determining how much aid a student is eligible for based on their withdrawal date and the specific requirements for disbursing funds; Regularly reviewing and analyzing post withdrawal disbursement data to identify any patterns or discrepancies that may indicate fraud or abuse. This includes a review of the financial records and transactions associated with each disbursement, as well as a review of the documentation that supports these transactions; Working closely with other departments within the College, including Registrar?s Office and the Business Office, to ensure that any changes in a student?s enrollment status are properly communicated and documented. By taking these steps, the Financial Aid Office will ensure that post-withdrawal disbursements are made in accordance with federal regulations and institution policies, and that these funds are used only for their intended purposes. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Fall 2022
FAC accepted this audit on September 18, 2022 — management decision was due March 18, 2023.
Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Subsidized Direct loans. Further, we noted one of the 40 students (2.5%) were not properly awarded Pell. See Schedule of Findings and Questioned Costs for chart/table We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2020-002. Statistical sampling was not used in making sample selections. Questioned Costs: $5,019 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. 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 ▴2021-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2021 Criteria: 34 CFR 682.201 (a) (1-2) notes, ?(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) 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 states, ?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: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Subsidized Direct loans. Further, we noted one of the 40 students (2.5%) were not properly awarded Pell. See Schedule of Findings and Questioned Costs for chart/table We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2020-002. Statistical sampling was not used in making sample selections. Questioned Costs: $5,019 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2021-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2021 Condition: Two of the 40 student files we examined, we noted the students (5%) were not properly awarded Subsidized Direct loans. Further, we noted one of the 40 students (2.5%) were not properly awarded Pell. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2020-002. Statistical sampling was not used in making sample selections. Corrective Action Plan: There has been extensive retraining and new training regarding the financial aid packaging for new and returning students. In October 2021, we hired a new Director and Assistant Director in the Financial aid office. Additionally, we are creating a new ?Pell Match Report? report via Fully Dispersed to accurately match Pell eligibility with what is being packaged. Alexis Brown, Director of Financial Aid, will be responsible for generating the new report with the assistance of Fully Dispersed. Once a month we will run a report that indicates any changes in award eligibility since the previous month. Responsible Person for Correction Action Plan: Steven Lambert, VP of Inclusive Enrollment and Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Immediately
2020-002
The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 28 of the 40 students in the sample (70%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS. Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. 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 ▴2021-003 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2021 Criteria: 34 CFR 668.164 (a)(1) states ?Except as provided under paragraph (a)(2) of this section, 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 form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 28 of the 40 students in the sample (70%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College posted the batches incorrectly resulting in a variance in the date of the disbursement per the student account and the date per NSLDS. Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2021-003 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2021 Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 28 of the 40 students in the sample (70%). We consider this condition to be a material weakness in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: This has been addressed through training Chris Beck, Accounts Receivable Supervisor, on how to properly post entries in the student information system. This training was led by an outside consultant. Responsible Person for Correction Action Plan: Sarah Mouch, Vice President for Administration and Finance and Chris Beck, Accounts Receivable Supervisor Implementation Date for Corrective Action Plan: Completed
The College did not timely and accurately complete refund calculations in the Fall. The College did not complete refund calculations timely for 1 out of the population of 11 Fall withdrawals (9%). Upon withdrawal of the students the College had limited staff while working remotely and withdrawal calculations were delayed. 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 3 out of the population of 11 (27.3%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2020-004. Statistical sampling was not used in making sample selections. Questioned Costs: $340 Effect: The College has not timely completed Return to Title IV calculations for one student, which resulted in refunds being made late. Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. 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 ▴2021-004 ? 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, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2021 Criteria: 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. The College did not complete refund calculations timely for 1 out of the population of 11 Fall withdrawals (9%). Upon withdrawal of the students the College had limited staff while working remotely and withdrawal calculations were delayed. 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 3 out of the population of 11 (27.3%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2020-004. Statistical sampling was not used in making sample selections. Questioned Costs: $340 Effect: The College has not timely completed Return to Title IV calculations for one student, which resulted in refunds being made late. Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2021-004 ? 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, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2021 Condition: The College did not timely and accurately complete refund calculations in the Fall. The College did not complete refund calculations timely for 1 out of the population of 11 Fall withdrawals (9%). Upon withdrawal of the students the College had limited staff while working remotely and withdrawal calculations were delayed. 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 3 out of the population of 11 (27.3%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2020-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: All R2T4?s have been corrected with the accurate amount of aid each student was eligible to receive. Verification with the Registrar and Institutional Research regarding the academic calendar will take place on a monthly basis to ensure discrepancies are avoided in the future. Responsible Person for Correction Action Plan: Steven Lambert, VP of Inclusive Enrollment and Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Immediately
2020-004
The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a material weakness in internal control over compliance relating to the Special Tests and Provisions compliance requirement and is not a repeat finding. 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 ▴2021-005 ? 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, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2021 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. We consider this condition to be a material weakness in internal control over compliance relating to the Special Tests and Provisions compliance requirement and is not a repeat finding. 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.
2021-005 ? 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, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2021 Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a material weakness in internal control over compliance relating to the Special Tests and Provisions compliance requirement and is not a repeat finding. Corrective Action Plan: Reconciliation is being done on a monthly basis between financial aid and the business office. Responsible Person for Correction Action Plan: Sarah Mouch, Vice President for Administration and Finance and Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Completed
The College did not complete verification for one of 40 (2.5%) students tested. Adjusted gross income (AGI) per verification varied from the ISIR and was not updated. We consider this condition to be an instance of noncompliance relating to the Special Tests and Provisions compliance requirement and is not a repeat finding. Questioned Costs: N/A Cause and Effect: This condition was caused by an oversight in Financial Aid. Recommendation: We recommend the College ensure verification is completed for students selected, including the updating of information when verification notes a discrepancy from the ISIR. 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 ▴2021-006 ? 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, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2021 Criteria: 34 CFR 668.54(a) requires an institution to verify all applicable items specified for an application who is selected for verification. Condition: The College did not complete verification for one of 40 (2.5%) students tested. Adjusted gross income (AGI) per verification varied from the ISIR and was not updated. We consider this condition to be an instance of noncompliance relating to the Special Tests and Provisions compliance requirement and is not a repeat finding. Questioned Costs: N/A Cause and Effect: This condition was caused by an oversight in Financial Aid. Recommendation: We recommend the College ensure verification is completed for students selected, including the updating of information when verification notes a discrepancy from the ISIR. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2021-006 ? 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, Assistance Listing No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 - Year Ended June 30, 2021 Condition: The College did not complete verification for one of 40 (2.5%) students tested. Adjusted gross income (AGI) per verification varied from the ISIR and was not updated. We consider this condition to be an instance of noncompliance relating to the Special Tests and Provisions compliance requirement and is not a repeat finding. Corrective Action Plan: The Director of Financial Aid has been and will continue to review all information for each student on an individual basis. Additionally, each month a sample of 10 students will be pulled by the Director of Financial Aid to be reviewed again. Responsible Person for Correction Action Plan: Steven Lambert, VP of Inclusive Enrollment and Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: Immediately
FAC accepted this audit on April 29, 2021 — management decision was due October 29, 2021.
One of the 40 student files we examined, we noted one student (2.5%) who was not properly awarded Subsidized Direct loans. The College under awarded a student who was eligible to receive an additional $158 in Subsidized Direct loans. See Schedule of Findings and Questioned Costs for chart/table We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2019-002. Statistical sampling was not used in making sample selections. Questioned Costs: $158 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. 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 682.201 (a) (1-2) notes, ?(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) 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.? Condition: One of the 40 student files we examined, we noted one student (2.5%) who was not properly awarded Subsidized Direct loans. The College under awarded a student who was eligible to receive an additional $158 in Subsidized Direct loans. See Schedule of Findings and Questioned Costs for chart/table We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2019-002. Statistical sampling was not used in making sample selections. Questioned Costs: $158 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan
Condition: One of the 40 student files we examined, we noted one student (2.5%) who was not properly awarded Subsidized Direct loans. The College under awarded a student who was eligible to receive an additional $158 in Subsidized Direct loans. See Corrective Action Plan for chart/table Direct Loan Under- payment We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2019-002. Statistical sampling was not used in making sample selections. Corrective Action Plan: The College has contracted with an outside vendor to help ensure accurate packaging of Title IV funds and will continue to focus attention to ensuring 100% compliance in this area. Responsible Person for Correction Action Plan: Barbara Grimm, Interim Director of Financial Aid Implementation Date for Corrective Action Plan: Immediate
2019-002
The College did not report graduate status changes within 60 days for three out of twenty students (12%) tested. We consider this condition to be a significant deficiency 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 year finding 2019-003. Statistical sampling was not used in making sample selections. Questioned Costs: $0 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) 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) states ?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 Unsubusidized, 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 three out of twenty students (12%) tested. We consider this condition to be a significant deficiency 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 year finding 2019-003. Statistical sampling was not used in making sample selections. Questioned Costs: $0 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 graduate status changes within 60 days for three out of twenty students (12%) tested. We consider this condition to be a significant deficiency 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 year finding 2019-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: Collaborative effort between the Office of the Registrar, the Office of Financial aid, and Residence Life to make sure graduate and other student status changes are reported in a timely fashion. All parties will review their current reporting policies to ensure compliance with the Department of Education policies, and ensure reporting status changes on a monthly basis. Responsible Person for Correction Action Plan: Dianna Ruyle, Registrar Implementation Date for Corrective Action Plan: Immediate
2019-003
Of the seven student withdrawals reviewed for testing, five students (71%) had a post-withdrawal disbursement or Title IV funds to be returned. Of the five students all return of Title IV fund calculations were incorrect. It was determined the College used the incorrect total days in the Fall 2019 and Spring 2020 return of Title IV funds calculation, resulting in incorrect amounts of Title IV amounts returned for all withdrawn students. We consider this condition to be a material weakness relating to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $432 Effect: Incorrect formulas for return of Title IV funds calculations can result in incorrect amounts returned by the College. Recommendation: We recommend the College review all return of Title IV calculations when returning funds to ensure formulas are accurate so that miscalculations and oversights can be detected and corrected in a timely manner. 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 668.22 (e) states ?The amount of title IV grant or loan assistance that is earned by the student is calculated by (i) determining the percentage of title IV grant or loan assistance that has been earned by the student, and (ii) applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed), or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date?. 34 CFR 668.22 (f) states ?the percentage of the payment period or period of enrollment completed is determined (i) in the case of a program that is measured in credit hours, by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student's withdrawal date?(2)(i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. (ii) The total number of calendar days in a payment period or period of enrollment does not include - (A) Days in which the student was on an approved leave of absence; or (B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time?. Condition: Of the seven student withdrawals reviewed for testing, five students (71%) had a post-withdrawal disbursement or Title IV funds to be returned. Of the five students all return of Title IV fund calculations were incorrect. It was determined the College used the incorrect total days in the Fall 2019 and Spring 2020 return of Title IV funds calculation, resulting in incorrect amounts of Title IV amounts returned for all withdrawn students. We consider this condition to be a material weakness relating to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $432 Effect: Incorrect formulas for return of Title IV funds calculations can result in incorrect amounts returned by the College. Recommendation: We recommend the College review all return of Title IV calculations when returning funds to ensure formulas are accurate so that miscalculations and oversights can be detected and corrected in a timely manner. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: Of the seven student withdrawals reviewed for testing, five students (71%) had incorrect amounts of Title IV funds returned. Upon further review, it was determined the College used the incorrect total days in the Fall 2019 and Spring 2020 return of Title IV funds calculation, resulting in incorrect amounts of Title IV amounts returned for all withdrawn students. We consider this condition to be a material weakness relating to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: The College understands why this error was made and has corrected its calculation methodology for the total number of days in the term to only exclude any break of five days or more. Responsible Person for Correction Action Plan: Barbara Grimm, Interim Director of Financial Aid Implementation Date for Corrective Action Plan: Immediate
FAC accepted this audit on March 30, 2020 — management decision was due September 30, 2020.
Title IV funds not properly awarded and disbursed for three of the 40 student files tested (7.5%). ? One student was not properly awarded Unsubsidized Direct Loans. The College underawarded a student who was eligible to receive an additional $163 in Unsubsidized Direct loans. "See Schedule of Findings and Questioned Costs for chart/table" ? Two students were over awarded need-based Federal Work Study as a result of external and institutional scholarships and grants. We consider these conditions to be instances of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2018-003. Statistical sampling was not used in making sample selections. Questioned Costs: $7,120 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. 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 682.201 (a) (1-2) notes, ?(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) 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 675.5(a)(2) states ?an institution may only award FWS employment to a student if the award, combined with the other estimated financial assistance the student receives, does not exceed the student's financial need?. Condition: Title IV funds not properly awarded and disbursed for three of the 40 student files tested (7.5%). ? One student was not properly awarded Unsubsidized Direct Loans. The College underawarded a student who was eligible to receive an additional $163 in Unsubsidized Direct loans. "See Schedule of Findings and Questioned Costs for chart/table" ? Two students were over awarded need-based Federal Work Study as a result of external and institutional scholarships and grants. We consider these conditions to be instances of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2018-003. Statistical sampling was not used in making sample selections. Questioned Costs: $7,120 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: Title IV funds not properly awarded and disbursed for three of the 40 student files tested (7.5%). ? One student was not properly awarded Unsubsidized Direct loans. The College under awarded a student who was eligible to receive an additional $163 in Unsubsidized Direct loans. We consider these conditions to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2018-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: Out of the three student files reviewed, the institution is in agreement with the three miscalculations leading to the under awarding of direct loan and the over awarding of need based aid. All three student accounts have been corrected in CAMS. The student file that was under awarded $163 in Unsubsidized Direct Loan due to a state grant miscalculation has been notified via letter of the miscalculation and the additional Unsubsidized Loan has been placed on the student account. For the two students that were over awarded need-based aid, their Work Tuition Credit-Need has been reduced and Work Tuition Credit-Non Need has been credited in its place. The Office of Financial Aid implemented auto packaging for the 2019-2020 academic year. This system auto packages based upon the information imported into the CAMS database from the student's ISIR. In addition to auto packaging and to ensure accurate awards, we have now put in place a report that would identify students whose need-based aid has been over awarded. Blackburn College is engaging Sikich LLP regarding consulting services to include an evaluation of the determination of eligibility and aid packaging the Office of Financial Aid has completed for the Fall 2019 and Spring 2020 semester. Responsible Person for Corrective Action Plan: Alisha Kapp Implementation Date: Immediate
2018-003
The College did not report graduate status changes within 60 days for five out of twenty students (25%) tested. We consider this condition to be a significant deficiency 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 year finding 2018-008. Statistical sampling was not used in making sample selections. Questioned Costs: $0 Cause and 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 ▴2019-003 ? Student Financial Aid Cluster ? (a) Federal Work-Study program (b) Federal Direct Loan (c) Federal Pell Grant program (d) Supplemental Educational Opportunity Grant ? CFDA No. (a) 84.033 (b) 84.268 (c) 84.063 (d) 84.007 - Year Ended June 30, 2019 Criteria: 34 CFR 690.83 (b)(2) 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) states ?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 five out of twenty students (25%) tested. We consider this condition to be a significant deficiency 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 year finding 2018-008. Statistical sampling was not used in making sample selections. Questioned Costs: $0 Cause and 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 graduate status changes within 60 days for five out of twenty students (25%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: Collaborative effort between the Office of the Registrar and Office of Financial Aid to make sure graduate status changes are reported in a timely fashion. The Registrar will provide access to the Clearinghouse for the Director of Financial Aid to assist with timely reporting and view the timeline of reports due. Responsible Person for Corrective Action Plan: Dianna Ruyle Implementation Date: Immediate
2018-008
FAC accepted this audit on November 18, 2018 — management decision was due May 18, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-004
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-005
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on November 15, 2017 — management decision was due May 15, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on November 22, 2016 — management decision was due May 22, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and compliance status.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.