Eureka College

EIN: 370673484

UEI: R6AREHZ95QV5

Data as of August 27, 2026

Eureka College10 audit years13 findings5 repeat
10
Audit Years
13
Total Findings
5
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 31, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 1, 2026 (35 days from today).

What is a management decision? →
2025-001
Eligibility
REPEAT

We tested forty files, thirty-nine of which were Federal Direct Loan recipients, and one student did not receive the full amount of eligible Federal Direct Subsidized Loans. We consider this finding to be an instance of noncompliance. Cause: The condition was caused by an increase to eligible grade level loans during an academic year being increased toward the unsubsidized loan prior to increasing the subsidized loan. Effect: The result is a student received unsubsidized loans prior to receiving full subsidized loans. Questioned Costs: $0.00 Recommendation: We recommend the College reallocate the increased unsubsidized loan toward the student’s subsidized loan and increase controls over packaging direct loans. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

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2025-001 – Underawarded Federal Direct Subsidized Loan 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025. Criteria: A third year student can receive up to $5,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested forty files, thirty-nine of which were Federal Direct Loan recipients, and one student did not receive the full amount of eligible Federal Direct Subsidized Loans. We consider this finding to be an instance of noncompliance. Cause: The condition was caused by an increase to eligible grade level loans during an academic year being increased toward the unsubsidized loan prior to increasing the subsidized loan. Effect: The result is a student received unsubsidized loans prior to receiving full subsidized loans. Questioned Costs: $0.00 Recommendation: We recommend the College reallocate the increased unsubsidized loan toward the student’s subsidized loan and increase controls over packaging direct loans. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2025-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025. Criteria: A third year student can receive up to $5,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested forty files, thirty-nine of which were Federal Direct Loan recipients, and one student did not receive the full amount of eligible Federal Direct Subsidized Loans. We consider this finding to be an instance of noncompliance. Cause: The condition was caused by an increase to eligible grade level loans during an academic year being increased toward the unsubsidized loan prior to increasing the subsidized loan. Effect: The result is a student received unsubsidized loans prior to receiving full subsidized loans Management Response: Management agrees with the finding Corrective Action Plan: This was an oversight on this student during the packaging process between the two loan types. We have implemented improvements to ensure this will not recur in our financial aid processes and procedures. Responsible Person: Kevin Catron and the Office of Financial Aid Implementation Date: 7/1/2025

Prior Finding References

2024-003

About Eligibility →
2025-002
Special Tests & Provisions
REPEAT

We tested four drop students and found two incorrect refund calculations. We consider this finding to be a significant deficiency. Cause: The condition was caused by a miscalculation of total scheduled days over total days within the semester. Effect: The result is the Institution returned funds to the Department of Education that should have been retained by the Institution. Questioned Costs: $0.00 Recommendation: We recommend the College to credit $818 to the appropriate student accounts and increase controls over refund calculations. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

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2025-002 – Incorrect Refund Calculations 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025. Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested four drop students and found two incorrect refund calculations. We consider this finding to be a significant deficiency. Cause: The condition was caused by a miscalculation of total scheduled days over total days within the semester. Effect: The result is the Institution returned funds to the Department of Education that should have been retained by the Institution. Questioned Costs: $0.00 Recommendation: We recommend the College to credit $818 to the appropriate student accounts and increase controls over refund calculations. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2025-002 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025. Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested four drop students and found two incorrect refund calculations. We consider this finding to be a significant deficiency. Cause: The condition was caused by a miscalculation of total scheduled days over total days within the semester. Effect: The result is the Institution returned funds to the Department of Education that should have been retained by the Institution. Management Response: Management agrees with the finding Corrective Action Plan: The calculations missed the omission of the Spring Break days from the total days of the term. We have implemented improvements to ensure this will not recur in our financial aid processes and procedures. Responsible Person: Kevin Catron and the Office of Financial Aid Implementation Date: 7/1/2025

Prior Finding References

2024-006

About Special Tests and Provisions →

FY 2024-06-30

FAC accepted this audit on February 27, 2025 — management decision was due August 27, 2025.

2024-001
Cash Management
QUESTIONED COSTS

During our testing of thirty-seven draw downs, we noted four individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $25,712 Cause and Effect: The condition was caused by changes in students enrollment statuses that were not caught in their reconciliation process which resulted in them requesting funds from the Common Origination and Disbursement (COD) system although they were no longer eligible for disbursements in the Spring semester due to graduating, withdrawing, or other circumstances. As a result, the College is retaining federal monies longer than allowed. Recommendation: We recommend that the College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

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2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Criteria: 34 CFR 668.163, 668.166 notes, “the Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period.(34 CFR 668.163, 668.166)”. Condition: During our testing of thirty-seven draw downs, we noted four individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $25,712 Cause and Effect: The condition was caused by changes in students enrollment statuses that were not caught in their reconciliation process which resulted in them requesting funds from the Common Origination and Disbursement (COD) system although they were no longer eligible for disbursements in the Spring semester due to graduating, withdrawing, or other circumstances. As a result, the College is retaining federal monies longer than allowed. Recommendation: We recommend that the College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b)84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: During our testing of thirty-seven draw downs, we noted 4 individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid (JFA). Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

About Cash Management →
2024-002
Special Tests & Provisions
REPEAT

The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). 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 part 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: $0 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.

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2024-002 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. 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 COD system for 4 of 40 students in the sample (10%). 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 part 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: $0 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.

Corrective Action Plan

2024-002 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance and is part 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. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid. Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

Prior Finding References

2023-003

About Special Tests and Provisions →
2024-003
Eligibility
REPEATQUESTIONED COSTS

Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is part 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: $809 Cause and Effect: For the awards, 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.

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2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. 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: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is part 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: $809 Cause and Effect: For the awards, 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.

Corrective Action Plan

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Management Response: Management agrees with the finding Corrective Action Plan: Loan calculations are automatic as part of JFA. Any manual changes to these loan amounts will be documented on the student file to justify differing amounts. Responsible Person: Tim Marten Implementation Date: 7/01/2024

Prior Finding References

2023-003

About Eligibility →
2024-004
Eligibility
REPEAT

One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. 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 2023-004. 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. 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.

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2024-004 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Criteria: 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: One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. 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 2023-004. 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. 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.

Corrective Action Plan

2024-004 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Management Response: Management agrees with the finding Corrective Action Plan: Pell calculations are automatic as part of JFA. Any manual changes to Pell grant amounts will be documented on the student file to justify differing amounts. The only way an amount should differ is if a student is close to their SULA and/or less than full time. Responsible Person: Tim Marten Implementation Date: 7/01/2024

Prior Finding References

2023-004

About Eligibility →
2024-005
Reporting

The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements. Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

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2024-005 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Criteria: 34 CFR 674.19 (d)(2) states “Each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary. Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. Cause and effect: Without proper controls in place, the College may not meet specified reporting requirements. Recommendation: We recommend the College evaluate policies and procedures to ensure all required supports are submitted timely and accurately. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2024-005 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: FISAP will be completed by September 15th each year. Plan is in place to ensure access to a wet signature. Prior late submission was due to staffing change and rejected application. Responsible Person: Tim Marten and Michael Bauman Implementation Date: 7/01/2024

About Reporting →
2024-006
Special Tests & Provisions
QUESTIONED COSTS

The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 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 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $3,448 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.

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2024-006 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. 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 Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 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 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $3,448 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.

Corrective Action Plan

2024-006 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 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 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: JFA did not accurately include days of breaks for Spring Break. A manual R2T4 calculation is in place to catch errors in the days in a semester. Responsible Person: Tim Marten Implementation Date: 7/01/2024

About Special Tests and Provisions →
2024-007
Special Tests & Provisions

The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Questioned Costs: N/A Cause and Effect: The College experienced turnover in which it is believed that reconciliations of Direct Loan funds were not completed. Further, the College’s Financial Aid system had overwritten all reconciliations that had been completed for the year ended June 30, 2024. Therefore no documentation was able to be provided to support that reconciliations of Direct Loan funds were completed. Recommendation: We recommend the College implement procedures in order to complete and retain 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.

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2024-007 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. 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 significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Questioned Costs: N/A Cause and Effect: The College experienced turnover in which it is believed that reconciliations of Direct Loan funds were not completed. Further, the College’s Financial Aid system had overwritten all reconciliations that had been completed for the year ended June 30, 2024. Therefore no documentation was able to be provided to support that reconciliations of Direct Loan funds were completed. Recommendation: We recommend the College implement procedures in order to complete and retain 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.

Corrective Action Plan

2024-007 - 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: JFA deletes prior reconciliation reports. Separate file location on the cloud has been created to hold these monthly reconciliation files. Corresponding reconciliation within Sonis (see above corrective action plan for excess cash) will also occur. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

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FY 2023-06-30

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

2023-001
Activities Allowed or Unallowed
QUESTIONED COSTS

During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $2,565 Cause and Effect: Without proper review of hours worked, 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 are being paid for hours worked that have been certified by the recipients’ supervisor. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

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2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 675.19 (b)(2) notes “The institution must also establish and maintain program and fiscal records that (i) Include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours worked in clock time sequence, or the total hours worked per day…” Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $2,565 Cause and Effect: Without proper review of hours worked, 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 are being paid for hours worked that have been certified by the recipients’ supervisor. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Management response: Timecard approval was completed by email notification. During 2022/23, a new email system was installed, and many emails related to timecards were lost. Corrective Action Plan: Starting in August 2023 all timecard approvals were documented in the payroll system (Paycor). HR prior to processing payroll requires all timecards be system documented as approved. Responsible Person: Kathleen Hermacinski, Human Resources Coordinator Implementation Date: August 2023

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2023-002
Special Tests & Provisions

The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance. 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.

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2023-002 – 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 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 ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance. 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.

Corrective Action Plan

2023-002 – 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: The College did not report graduate status changes within 60 days for ten out of twenty students (50%) tested. We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance. Management response: From October 2022 to August 2023, the Registrar's Office was short staffed (we only had one employee in the office). We also switched email service providers in the second half of May 2023. The degree file reminder email from the National Student Clearinghouse was missed by the Registrar in the email transition period and because of the change in calendar systems, it was also missed on the Registrar's calendar. When the email migration was complete, the Registrar had thousands emails that were showing as unread. By the time the email cleanup was complete, and the Registrar realized she had not submitted the May 2023 degree file, the 60 day window had passed. The file was submitted in late July as soon as it was discovered that it hadn't gotten submitted (15 days past the 60 day window) Corrective Action Plan: The Summer 2023 and Fall 2023 degree files were submitted on time. The Registrar's office is once again fully staffed and our email and calendar systems are stable again as well. Responsible Person: Kendi Onnen, Registrar Implementation Date: 7/27/2023

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2023-003
Eligibility
QUESTIONED COSTS

We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, 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 these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,252 Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. For the disbursement date, 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 evaluate policies and procedures to ensure students receive the proper amount of Title IV aid and 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.

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2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 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.” 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: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, 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 these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,252 Cause and Effect: For the awards, without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. For the disbursement date, 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 evaluate policies and procedures to ensure students receive the proper amount of Title IV aid and 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.

Corrective Action Plan

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, 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 these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Management Response: Cost of Attendance (COA) calculations were not updated to ensure ratio of subsidized versus unsubsidized loans were correct. It looks like awards were not being recalculated as additional need based aid was added to awards for these students. Corrective Action Plan: New financial aid software (JFA) was implemented for the 2023-2024 academic year. A component of this software is a compliance check for COA and other issues. The compliance check for over awards should catch instances of the wrong sub/unsub ratio in the future. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Fall 2023

About Eligibility →
2023-004
Eligibility

We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. 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. Students should receive the proper amount of aid. Recommendation: We recommend the University 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

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2023-004 – 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 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: We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. 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. Students should receive the proper amount of aid. Recommendation: We recommend the University 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

Corrective Action Plan

2023-004 – 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 (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted one student was not properly awarded their Pell grant. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Management Response: This was a student transferring from a college that had closed (Lincoln College) the Financial Aid staff did not calculate new PELL eligibility with the Eureka College COA and awarded Pell from the wrong matrix on the Pell payment chart. Corrective Action Plan: All pell awards are now being offered based on correct COA and Pell Grant matrix with the Eureka costs. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Spring 2024

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