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Southwestern Illinois Community College District #522Higher Education

EIN: 370896981

UEI: GLAJF337HDG5

Audited by: CliftonLarsonAllen LLP

Oversight agency: 84 [Department of Education]

View federal awards & risk assessment →

Data as of August 31, 2026

Southwestern Illinois Community College District #52210 audit years16 findings2 repeat
10
Audit Years
16
Total Findings
2
Repeat Findings
$21M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$21,038,332 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 18, 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 September 18, 2026 (17 days from today).

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FY 2024-06-30

$23,572,805 federal awards expended

FAC accepted this audit on January 14, 2025 — management decision was due July 14, 2025.

2024-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The College did not have a formal review process in place as well as submit report timely. Context: During our testing, we identified 2 out of 2 financial reports did not have documentation of formal review. Additionally, 1 of the 2 reports was not submitted within the required timeframe. Questioned costs: None. Cause: Supervisory review and approval is currently undocumented, and is only communicated verbally. Effect: Improper data could be submitted to the awarding agency. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Views of responsible officials: Management agrees with the finding.

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2024-001 Reporting Federal agency: U.S Department of Commerce Federal program title: Investments for Public Works and Economic Development Facilities Assistant Listing Number: 11.300 Federal Award Identification Number: 05-79-06232 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Compliance, Other Matters  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 reports are formally reviewed by someone who did not prepare the report to verify the correct information and data is submitted. Additionally, per 2 CFR 200.328(c) the recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Condition: The College did not have a formal review process in place as well as submit report timely. Context: During our testing, we identified 2 out of 2 financial reports did not have documentation of formal review. Additionally, 1 of the 2 reports was not submitted within the required timeframe. Questioned costs: None. Cause: Supervisory review and approval is currently undocumented, and is only communicated verbally. Effect: Improper data could be submitted to the awarding agency. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Routine communication between program directors and accounting staff will include discussion of reporting timeline in order to ensure timely submission. The Finance Department will review and approve required reports that are prepared by grant program directors. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler, Chief Financial Officer Planned completion date for corrective action plan: February 28, 2025.

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2024-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect 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 accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.

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2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Compliance, Other Matters  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 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 used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect 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 accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The records identified with incorrect R2T4 calculations have been recalculated, reported to COD and funds returned. In order to best ensure policies and procedures for R2T4 calculations, additional staff have been trained to ensure calculations are checked and double checked to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson, Director of Financial Aid, Veteran Services & Student Employment Planned completion date for corrective action plan: All corrections have been submitted as of October 9, 2024. Training of additional staff in progress – to be completed by February 28, 2025.

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2024-003
Cost Allowability
MATERIAL WEAKNESSOTHER MATTERS

The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.

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2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding:  Compliance, Other Matters  Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. 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 did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2024-003 Career and Technical Education – Basic Grant to States – Assistance Listing No. 84.048 Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will conduct an annual review and certification of time and effort. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2025

About Allowable Costs / Cost Principles →

FY 2023-06-30

$18,316,902 federal awards expended

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

2023-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were certain required elements missing from the institution’s Written Information Security Program (WISP). Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No. Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: Management agrees with the finding.

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2023-001 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matters • Significant Deficiency in Internal Control over Compliance 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)). 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 University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were certain required elements missing from the institution’s Written Information Security Program (WISP). Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No. Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the College has updated the WISP with all required elements and will incorporate into board policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name(s) of the contact person(s) responsible for corrective action: Linda Andres Planned completion date for corrective action plan: 6/30/24

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2023-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The College did not timely report all disbursement dates and amounts to the COD system. Context: We identified 2 out of 40 COD disbursements tested that were not reported within the required 15 days to COD, these two instances were reported 7 days late. Questioned costs: None. Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat Finding: No. Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Views of responsible officials: Management agrees with the finding.

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2023-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. 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 did not timely report all disbursement dates and amounts to the COD system. Context: We identified 2 out of 40 COD disbursements tested that were not reported within the required 15 days to COD, these two instances were reported 7 days late. Questioned costs: None. Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat Finding: No. Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2023-002 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will closely monitor submission dates and work quickly to resolve technology or other discrepancies that result in delays in file transfer to COD within 15 days of the disbursement date. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24

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2023-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The College did not timely refund credit balances to the student or parent. Context: We identified 1 out of 40 students tested that was not refunded within the required 14 days, the credit balance was refunded 7 days late. Questioned costs: None. Cause: The Student Financial Aid office had an automated process to ensure all refunds were issued in 14 days failed to recognize a credit balance in a student's account. Effect: The student did not have access to Title IV funds timely after disbursement. Repeat Finding: No. Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Views of responsible officials: Management agrees with the finding.

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2023-003 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires that Title IV credit balances must be paid to the student or parent no later than 14 days after the credit balance occurred. (34 CFR 164(h)(2)). 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 did not timely refund credit balances to the student or parent. Context: We identified 1 out of 40 students tested that was not refunded within the required 14 days, the credit balance was refunded 7 days late. Questioned costs: None. Cause: The Student Financial Aid office had an automated process to ensure all refunds were issued in 14 days failed to recognize a credit balance in a student's account. Effect: The student did not have access to Title IV funds timely after disbursement. Repeat Finding: No. Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will conduct a manual review of all refund holds to ensure they are removed to allow timely pay of Title IV credit balances. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24

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2023-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The college had the required information on their website but had not disclosed the URL to the Department of Education. Context: The college published the contract, assessed fees, and terms and conditions, however, they did not properly report the URL to Department of Education. Questioned costs: None. Cause: The contract is in its first year of operations, and the URL was not submitted within 60 days after award year. Effect: The college was not in compliance with Title IV third-party servicer compliance. Repeat Finding: No. Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Views of responsible officials: Management agrees with the finding.

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2023-004 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires that the college provide to the Secretary an up-to-date Uniform Resource Locator (URL) for the contract for publication in a centralized database to the public. (34 CFR 668.164(f)(4)(iii)(B)). 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 had the required information on their website but had not disclosed the URL to the Department of Education. Context: The college published the contract, assessed fees, and terms and conditions, however, they did not properly report the URL to Department of Education. Questioned costs: None. Cause: The contract is in its first year of operations, and the URL was not submitted within 60 days after award year. Effect: The college was not in compliance with Title IV third-party servicer compliance. Repeat Finding: No. Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will monitor Dear Colleague Letters and the Federal Student Aid Handbook to ensure compliance with disclosures and reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/24

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2023-005
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 5 students that were reported past the 60-day reporting timeframe to NSLDS. These student enrollment dates were reported 12 days late. Questioned costs: None. 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: 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. Views of responsible officials: Management agrees with the finding.

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2023-005 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A221105 - P033A221105 - P063P221336 - P268K231336 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 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. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date 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 did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 5 students that were reported past the 60-day reporting timeframe to NSLDS. These student enrollment dates were reported 12 days late. Questioned costs: None. 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: 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. Views of responsible officials: Management agrees with the finding.

Corrective Action Plan

2023-005 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely. Explanation of disagreement with audit finding: The college disagrees with this finding, related to the reporting of five graduate files to NSLDS. The finding states the five files were reported 12 days late of the 60-day reporting requirement. Per section 4.4.2 of the NSLDS Reporting Guide, it is not required that an update be received by NSLDS within two months of the Enrollment Status Effective Date, but rather in the next scheduled enrollment submission. Evidence the graduation status was reported in the next scheduled enrollment submission was provided to the auditors. Action taken in response to finding: The College will continue to closely monitor NSC/ NSLDS reporting schedule and check for transmission errors to ensure compliance with reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24

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FY 2022-06-30

LOW-RISK AUDITEE$28,279,572 federal awards expended

FAC accepted this audit on May 9, 2023 — management decision was due November 9, 2023.

2022-001
Cash Management
SIGNIFICANT DEFICIENCY

2022-001 Cash Management Federal agency: U.S Department of Education Federal program title: Higher Education Emergency Relief Fund Assistant Listing Number: 84.425E / 84.425F Federal Award Identification Number: P425E203569 / P425F203111 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal 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. The College is required to have proper established controls over its cash management process related to cash drawdowns from the G5 system. Condition and Context: The College did not have a formal documented review process in place to ensure G5 drawdowns were reviewed prior to submitting the drawdown request. Questioned costs: None. Cause: The College did not properly implement internal control procedures over cash management procedures pertaining to its cash drawdowns from the G5 system. Effect: Failure to properly review Cash Management drawdowns could result in an improper amount of funds being requested. Repeat Finding: No. Recommendation: We recommend the College implement controls related to cash management that designates a different reviewer and signer of drawdowns that occur within a given year. Views of responsible officials and management?s response: The College agrees with the finding.

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2022-001 Cash Management Federal agency: U.S Department of Education Federal program title: Higher Education Emergency Relief Fund Assistant Listing Number: 84.425E / 84.425F Federal Award Identification Number: P425E203569 / P425F203111 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal 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. The College is required to have proper established controls over its cash management process related to cash drawdowns from the G5 system. Condition and Context: The College did not have a formal documented review process in place to ensure G5 drawdowns were reviewed prior to submitting the drawdown request. Questioned costs: None. Cause: The College did not properly implement internal control procedures over cash management procedures pertaining to its cash drawdowns from the G5 system. Effect: Failure to properly review Cash Management drawdowns could result in an improper amount of funds being requested. Repeat Finding: No. Recommendation: We recommend the College implement controls related to cash management that designates a different reviewer and signer of drawdowns that occur within a given year. Views of responsible officials and management?s response: The College agrees with the finding.

Corrective Action Plan

2022-001 Higher Education Emergency Relief Fund ? CFDA No. 84.425E; 84.425F Recommendation: We recommend that the College implement controls related to cash management that designates a different reviewer and signer of drawdowns that occur within a given year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of audit finding and 2022-001, the College implemented a process that includes formalized review and approval of drawdowns of federal awards. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/23

About Cash Management →

FY 2021-06-30

LOW-RISK AUDITEE$27,275,619 federal awards expended

FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.

2021-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2020-002

2021-001 NSLDS Enrollment Reporting Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. The Code of Federal Regulations, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition and Context: During our testing, we noted that for one out of the 40 students tested, the withdrawal date reported to NSLDS did not match the College?s Records. Questioned costs: None. Cause: The College did not properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). The enrollment effective date errors were related to human error and changes in staffing. Effect: Failure to properly report withdrawal dates on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Repeat Finding: Yes, 2020-002. Recommendation: We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. Views of responsible officials and management?s response: The College agrees with the finding.

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2021-001 NSLDS Enrollment Reporting Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. The Code of Federal Regulations, 34 CFR 685.309, requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition and Context: During our testing, we noted that for one out of the 40 students tested, the withdrawal date reported to NSLDS did not match the College?s Records. Questioned costs: None. Cause: The College did not properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). The enrollment effective date errors were related to human error and changes in staffing. Effect: Failure to properly report withdrawal dates on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Repeat Finding: Yes, 2020-002. Recommendation: We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. Views of responsible officials and management?s response: The College agrees with the finding.

Corrective Action Plan

2021-001 Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the Bursar's office and the financial aid office work with NCS to ensure error record corrections are re-submitted and are received by NSLDS within the 10 day timeframe required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of audit findings 2020-001 and 2020-002, the College began a full and comprehensive review of the enrollment reporting process and subsequent error resolution. Beginning January 2022, a modified review process was implemented, resulting in improved timely and accurate reporting in NSC and NSLDS. This process is subject to ongoing review as unique enrollment scenarios are identified as resulting in reporting errors. Moving forward the College will develop a manual review process of populations at risk for date discrepancies, such as R2T4, to ensure correction. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/22

Prior Finding References

2020-002

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FY 2020-06-30

LOW-RISK AUDITEE$18,385,373 federal awards expended

FAC accepted this audit on May 12, 2021 — management decision was due November 12, 2021.

2020-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

During our testing, we noted that the rosters returned for the College yielded error reports that were not corrected and resubmitted within the required 10 days throughout the year. Questioned Costs: None Context: During the year, 3 error records repeated the majority of the year under audit. It appears management initially attempted to correct errors, although, when errors repeated, there was no evidence management attempted to resolve the errors. Cause: Management indicated that enrollment status changes were sent to NSC within the 10 day timeframe, but due to delays at NSC, NSLDS did not receive the corrections within the 10 day timeframe required and they were not followed up on. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend that the Business Office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the ten-day timeframe required. Views of responsible officials: Management indicated that enrollment status changes were sent to NSC within the 10 day timeframe, but due to delays at NSC, NSLDS did not receive the corrections within the 10 day timeframe required and they were not followed up on.

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2020 ? 001 National Student Loan Data System (NSLDS) Error Correcting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted that the rosters returned for the College yielded error reports that were not corrected and resubmitted within the required 10 days throughout the year. Questioned Costs: None Context: During the year, 3 error records repeated the majority of the year under audit. It appears management initially attempted to correct errors, although, when errors repeated, there was no evidence management attempted to resolve the errors. Cause: Management indicated that enrollment status changes were sent to NSC within the 10 day timeframe, but due to delays at NSC, NSLDS did not receive the corrections within the 10 day timeframe required and they were not followed up on. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend that the Business Office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the ten-day timeframe required. Views of responsible officials: Management indicated that enrollment status changes were sent to NSC within the 10 day timeframe, but due to delays at NSC, NSLDS did not receive the corrections within the 10 day timeframe required and they were not followed up on.

Corrective Action Plan

2020-001 Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is implementing a full, comprehensive review of the enrollment reporting process and subsequent error resolution. This review will begin immediately, incorporating guidance from the NSC audit response team on strategies to ensure future compliance. Name(s) of the contact person(s) responsible for corrective action: Christopher Melvin Planned completion date for corrective action plan: 6/30/21

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2020-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

During our testing, we noted that six out of the 40 students tested, the program begin date reported to NSLDS did not match the College?s Records for first date of attendance in the corresponding reported program. We also noted that one out of the 40 students tested, was not reported to NSLDS Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The College did not timely or accurately report student enrollment information to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: Students were initially admitted to the College with the Program Enrollment date reflected in NSLDS. Students then enrolled in a later term, and the enrollment date and withdrawal status were submitted to NSC in proper manner. We recognize our role and responsibility to the timely submission of data to NSLDS. We will review the current processes and procedures to ensure we are in full compliance.

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2020 ? 002 NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted that six out of the 40 students tested, the program begin date reported to NSLDS did not match the College?s Records for first date of attendance in the corresponding reported program. We also noted that one out of the 40 students tested, was not reported to NSLDS Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The College did not timely or accurately report student enrollment information to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: Students were initially admitted to the College with the Program Enrollment date reflected in NSLDS. Students then enrolled in a later term, and the enrollment date and withdrawal status were submitted to NSC in proper manner. We recognize our role and responsibility to the timely submission of data to NSLDS. We will review the current processes and procedures to ensure we are in full compliance.

Corrective Action Plan

2020-002 Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the Bursar's office and the financial aid office work with NCS to ensure error record corrections are re-submitted and are received by NSLDS within the 10 day timeframe required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is implementing a full, comprehensive review of the enrollment reporting process and subsequent error resolution. This review will begin immediately, incorporating guidance from the NSC audit response team on strategies to ensure future compliance. Name(s) of the contact person(s) responsible for corrective action: Christopher Melvin Planned completion date for corrective action plan: 6/30/21

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FY 2019-06-30

$18,841,007 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 14, 2020 — management decision was due July 14, 2020.

FY 2018-06-30

$20,671,207 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 20, 2019 — management decision was due August 20, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$22,312,666 federal awards expended

FAC accepted this audit on February 11, 2018 — management decision was due August 11, 2018.

2017-001
Procurement & Suspension/Debarment
MATERIAL WEAKNESSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-002
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-06-30

LOW-RISK AUDITEE$24,596,494 federal awards expended

FAC accepted this audit on November 20, 2016 — management decision was due May 20, 2017.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2015-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-001

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2016-002
Activities Allowed or Unallowed / Cost Allowability / Period of Performance / Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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