EIN: 370892167
UEI: DNE9Q5EKFKU5
Data as of August 25, 2026
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 (37 days from today).
What is a management decision? →The College performed an incorrect Return to Title IV (R2T4) calculation. Questioned costs: None Context: During our testing of 10 R2T4 calculations, we identified that one had mechanically incorrect calculation. Cause: The student was attending both modules within the Spring term while the calculation only included the second module. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes (2024-001) Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P241353-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.21(a), the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College performed an incorrect Return to Title IV (R2T4) calculation. Questioned costs: None Context: During our testing of 10 R2T4 calculations, we identified that one had mechanically incorrect calculation. Cause: The student was attending both modules within the Spring term while the calculation only included the second module. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes (2024-001) Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Student Financial Assistance Cluster Assistance Listing No. 84.063 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: FSA regulations pertaining to R2T4 calculations for students enrolled in modules have been reviewed. Updates have been made to our R2T4 process to include the use of a tool to clearly identify students attending in modules, and to determine the number of days in the term and days attended for these students. Financial Aid process manuals have been updated with practical examples of R2T4 calculations for students who have attended, and withdrawn from, courses of varying lengths within the same term. The updated process has been reviewed with all Financial Aid staff. R2T4 calculations already performed for FY26 on students that have attended in modules have been reviewed for accuracy. Erroneous calculations have been corrected. Name(s) of the contact person(s) responsible for corrective action: Sarah Ratermann, Director of Financial Aid. Planned completion date for corrective action plan: 3/17/2026
2024-001
During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements. Questioned costs: None. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs. Cause: The College is in process of updating written policies and procedures to address all of the required elements. Effect: Student personal information could be vulnerable. Repeat Finding: Yes (2024-003). Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements. Views of responsible officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P241353-2025, P007A241190-2025, & P033A241190-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements. Questioned costs: None. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs. Cause: The College is in process of updating written policies and procedures to address all of the required elements. Effect: Student personal information could be vulnerable. Repeat Finding: Yes (2024-003). Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements. Views of responsible officials: Management agrees with this finding.
Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.007, & 84.033 Recommendation: We recommend the College work to update the written information security program to ensure compliance with all the required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has updated the written information security program (WISP) to ensure compliance with all the required elements of the Gramm-Leach Bliley Act (GLBA). These updates were completed as of 8/25/2025. Name(s) of the contact person(s) responsible for corrective action: George Kriss, CIO and Vice President of Institutional Support & Technology at 618-548-3018. Planned completion date for corrective action plan: 8/25/2025
2024-003
The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 40 students, we identified 2 students had the incorrect effective date reported to NSLDS, and 5 student status changes that were not reported to NSLDS in a timely manner. Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes (2024-002). Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P241353-2025, P007A241190-2025, & P033A241190-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 40 students, we identified 2 students had the incorrect effective date reported to NSLDS, and 5 student status changes that were not reported to NSLDS in a timely manner. Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes (2024-002). Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with this finding.
Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.007, & 84.033 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Institutional Research has reached out to the National Student Clearinghouse regarding a status of Graduated not generated for students reported as graduates. It was discovered that when multiple degree records are submitted in a single DegreeVerify file for the same student, a Graduated status may not be generated, even when separate program detail records exist. Guidance provided by the National Student Clearinghouse regarding DegreeVerify (G from DV) reporting, specifically as it relates to multiple degree records submitted for the same student within the same file. An additional verification step has been incorporated into internal reporting processes to identify students whose Graduated status may not have been generated due to multiple degree records submitted in the same file. This updated process will allow staff to proactively confirm that Graduated statuses are successfully transmitted to NSLDS through the Enrollment Reporting process when necessary. Institutional Research is conducting a comprehensive review of all documentation and procedures related to National Student Clearinghouse reporting, including DegreeVerify and Enrollment Reporting submissions, to ensure procedures are current and effective in maintaining compliance with federal reporting requirements. The office of Institutional Research is conducting a review of graduates within the past two reporting cycles (two years) to identify and correct the records of any students impacted by this issue. Institutional Research staff have been trained on the updated procedures. Name(s) of the contact person(s) responsible for corrective action: James Anderson, Director of Institutional Effectiveness Planned completion date for corrective action plan: 05/15/2026
2024-002
FAC accepted this audit on June 17, 2025 — management decision was due December 17, 2025.
The College incorrectly calculated Return to Title IV (R2T4) calculations. Questioned costs: None Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days. Cause: The College was using the incorrect number of scheduled break days for Fall Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes (2023-001) Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024, P033A231190-2024, & P007A231190-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(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. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations. Questioned costs: None Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days. Cause: The College was using the incorrect number of scheduled break days for Fall Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: Yes (2023-001) Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Action taken in response to finding: As a result of the 2023 audit, which concluded in May of 2024, adjustments were made to reflect a five day fall break for Fall 2024. R2T4 calculations for Fall 2024 have been reviewed and the use of a five-day break for the term has been verified. The Fall 2025 term has already been built in Colleague to reflect a five day fall break. The Fall 2023 term was built in Colleague by the previous Director of Financial Aid. The current Director of Financial Aid has recognized a five-day break when building the fall terms in Colleague and will continue this practice for future terms. In following our recently updated R2T4 process, all Financial Aid staff members have been trained and are able to perform R2T4 calculations. R2T4 calculations for the 2024-2025 academic year have been performed by Financial Aid staff and have been reviewed for accuracy and approved by the Director of Financial Aid.
2023-001
The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment. Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024, P033A231190-2024, & P007A231190-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None. Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment. Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with this finding.
Action taken in response to finding: Admissions training manuals have been updated to ensure that the date the student first indicated a desire to withdraw from a course is used as the date of withdrawal rather than the date that the withdrawal was processed in Colleague. Admissions staff members have been trained on the updated procedure for processing student course withdrawals. The Office of Institutional Research has reviewed and updated the procedures used to generate reports sent to National Student Clearinghouse. IR staff members will ensure that the last date of attendance is reported for student course withdrawals. The office of Institutional Research has contacted National Student Clearinghouse for guidance on the enrollment reports needed to ensure that student enrollment is reported to NSLDS accurately and timely. An additional enrollment report will now be sent to National Student Clearinghouse for reporting graduated students. This will ensure that students that have graduated are reported as no longer enrolled within the required reporting timeframe.
During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements. Questioned costs: None. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs. Cause: The College is in process of updating written policies and procedures to address all of the required elements. Effect: Student personal information could be vulnerable. Repeat Finding: No. Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements. Views of responsible officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024, P033A231190-2024, & P007A231190-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements. Questioned costs: None. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs. Cause: The College is in process of updating written policies and procedures to address all of the required elements. Effect: Student personal information could be vulnerable. Repeat Finding: No. Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements. Views of responsible officials: Management agrees with this finding.
Action taken in response to finding: The College will work to update the written information security program (WISP) to ensure compliance with all the required elements of the Gramm-Leach Bliley Act (GLBA).
FAC accepted this audit on May 21, 2024 — management decision was due November 21, 2024.
The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Action taken in response to finding: Adjustments have been made to reflect the full spring break period in our return of funds process. The number of days campus is considered to be closed for spring break has been updated to nine days for Spring 2024. Spring terms in the future will be set up in Colleague with the day following the last day of classes prior to spring break as the first day of spring break and the day prior to the first day of classes after spring break as the last day of spring break. For 2023-2024 and 2024-2025, this equates to a nine-day spring break. All R2T4 calculations for Spring 2024 have been reviewed and recalculated using a nine-day spring break rather than a seven-day spring break. In communicating with Ellucian regarding the processing of R2T4, we discovered a report that we can run in Colleague to identify students that have withdrawn from all courses and will not complete any courses for the semester. This will be used instead of the report made in house, previously utilized for this process. A financial aid staff member will run the report and perform the R2T4 calculations in Colleague. Then the staff member that performed the calculations will run the Return of Funds Detail Report in Colleague, indicate on that report that they performed the calculations, and send the report to the Director of Financial Aid. The Director will review the Return of Funds Detail Report and the calculations. The Director will sign off on the Return of Funds Detail Report approving the calculations. The report will then be saved in the Return of Funds folder in the Financial Aid Files. All Financial Aid staff members will be trained and have the ability to perform R2T4 calculations to ensure that the calculations can be performed regularly prior to each student refund date during the term. All R2T4 calculations for the 2023-2024 school year have been reviewed for accuracy. Calculations performed for the fall 2023 semester have been reviewed by the Director of Financial Aid for accuracy. Due to short staffing in the Financial Aid Office in the spring semester, and remaining staff not being trained on the R2T4 process, calculations for the Spring 2024 semester were performed by the Director of Financial Aid. To ensure the accuracy of the calculations, the calculations were checked using the R2T4 calculation tool in COD (Common Origination Disbursement).
The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Action taken in response to finding: The College started to immediately document the SAM check on every purchase requisition, check request, travel request and new vendor entry with IRS Form W-9. The College is also collecting the certification from vendors as part of the bid process. The College has also updated the process document for these actions.
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.
Action taken in response to finding: will include Institutional Research compiling the data and then sending to Financial Aid/Admissions for review of the enrollment files. The Financial Aid/Admissions department will test a sample of the student enrollment data that it is correct. The Department will maintain evidence of the review and confirm back to Institutional Research the review has been completed. Institutional Research can then submit the enrollment files to the National Student Clearinghouse.
FAC accepted this audit on November 16, 2016 — management decision was due May 16, 2017.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
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