EIN: 381357980
UEI: J248CHZUAND3
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2024. 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 30, 2024 (692 days ago).
What is a management decision? →Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date. 2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process. Note: • Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding. • Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding. There were no questioned costs associated with the finding.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material noncompliance with laws and regulations Repeat Finding - No Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date. 2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process. Note: • Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding. • Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding. There were no questioned costs associated with the finding.
Condition: The College did not report certain students’ status to the National Student Loan Data System (NSLDS) in an accurate and timely manner during the fiscal year. Context - There were two errors identified that attributed to this finding: 1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date. 2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. Planned Corrective Action: The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process. Note: • Re status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty-eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third-party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding. Re student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third-party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Andrea Milner VP Academic Affairs/Dean Anticipated Completion Date: Academic Year 2023-2024
Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1)) Condition - Certain credit balances were not refunded to students within 14 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations. Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days. Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period. Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students. There were no questioned costs associated with the finding
Show full finding ▾Hide full finding ▴Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: (i) 14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1)) Condition - Certain credit balances were not refunded to students within 14 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations. Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days. Views of Responsible Officials and Planned Corrective Actions - The manager of student business services, working with the director of financial aid, will inform the vice president of business affairs those students who are scheduled to receive special supplemental institutional aid (see below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required 14-day period. Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (The Godard Scholarship). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their accounts. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students. There were no questioned costs associated with the finding
Condition: Certain credit balances were not refunded to students within the required fourteen (14) days. Context - Of the 25 students tested, there was 1 student who had credit balances created by Title IV funds that were not refunded within 14 days. Planned Corrective Action: The Manager of Student Business Services, working with the Director of Financial Aid, will identify to the Vice-President of Business Affairs (VPBA) those students who are scheduled to receive special supplemental institutional aid (refer to Note below) and identify if that supplemental aid amount will place the student in a credit balance. The VPBA will then determine if the supplemental aid amount should be adjusted. If there is no adjustment, any credit balance will be processed for refund within the required fourteen (14) day period. Note: This finding relates to a certain classification of students who receive supplemental intuitional aid in the form of a special scholarship (“The Godard Scholarship”). The intent of the scholarship was to supplement other forms of financial aid available to students such that the student’s account balance would equal zero. The scholarship amount was not adjusted from that originally communicated to students resulting in some students having a credit balance on their account. Rather than reducing the scholarship amount, the administration elected to honor that amount initially communicated to the scholarship recipients. The timing of this decision contributed to refund payments being delayed beyond the allowable period for this certain classification of students. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Jerry Wright VP Business Affairs/CFO Anticipated Completion Date: Academic Year 2023-2024
Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F. Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact: $38,970,352 loan under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect. Recommendation - The College should implement process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F. Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact: $38,970,352 loan under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect. Recommendation - The College should implement process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Planned Corrective Action - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
2022-002
FAC accepted this audit on March 30, 2024 — management decision was due September 30, 2024.
Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F. Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact: $38,970,352 received under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect. Recommendation - The College should implement process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
Show full finding ▾Hide full finding ▴Assistance Listing, Federal Agency, and Program Name - ALN 10.766, Department of Agriculture, Community Facilities Loans and Grants Federal Award Identification Number and Year - N/A Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Prior to issuance of the 2022 Compliance Supplement the USDA instructed borrowers that loans under ALN 10.766 did not have continuing compliance requirements and thus were not required to be audited under 2 CFR Part 200 Subpart F in the years after project completion. However, with the issuance of the 2022 Compliance Supplement the USDA changed this position and determined these loans have continuing compliance requirements and thus are subject to audit under 2 CFR Part 200 Subpart F. Condition - The schedule of expenditures of federal awards (SEFA) as originally issued did not include loans with continuing compliance requirements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Prior to the June 30, 2022 fiscal year end, the USDA did not classify loans outstanding under ALN 10.766 as having continuing compliance requirements. The USDA changed its position and began treating these loans as having continuing compliance and issued a notice to loan recipients that they must report the loan balances on their schedule of expenditures of federal awards beginning with fiscal years ending June 30, 2022. The College did not identify this change in policy and incorrectly excluded the loan entered into during the year ($38,970,352) from the originally issued schedule of expenditures of federal awards. Cause and Effect - Controls in place did not ensure the SEFA was complete and accurate. The resulting error had the following impact: $38,970,352 received under ALN 10.766 was excluded from the total expenditures reported on the SEFA, resulting in the initial major program determination being incorrect. Recommendation - The College should implement process to ensure that the SEFA is complete and accurate. Views of Responsible Officials and Corrective Action Plan - In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate.
In December 2023 management identified that with its participation as borrower on a Community Facilities Loan, guaranteed by the USDA, that it had a compliance obligation to include the loan program in the SEFA. The College has designed and implemented controls that require the VP of Business Affairs (or designee) to identify new and modified compliance and reporting obligations under the currently enrolled programs or for any new programs in which the College may participate
FAC accepted this audit on December 15, 2021 — management decision was due June 15, 2022.
ALN Number, Federal Agency, and Program Name - Department of Education - Federal Perkins Loan Program ALN 84.038 Federal Award Identification Number and Year - Unknown Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Institutions must maintain copies of master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Disbursement records, electronic authentication and signature records for loans made with an MPN must also be retained by the institution. Institutions are required to keep original paper promissory notes or original paper MPNs and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third party service provider for its Perkins Loan program, the institution must perform due diligence to ensure that the third party is in compliance with the requirements for the functions the third party service provider is performing for the school. Such due diligence could include obtaining and reviewing the third party's most recent Title IV compliance audit. (34 CFR 674.19.(e).) Condition - Of the 25 students tested, 1 student was identified to not have a master promissory note on file. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University and its third party loan service provider, ECSI, could not locate the master promissory note for a student. Cause and Effect - The University did not have an effective control in place to ensure that all open Perkins loan master promissory notes are kept. Recommendation - The University should implement controls to ensure Perkins master promissory notes are retained. Views of Responsible Officials and Corrective Action Plan - The College hired a new senior level Business & Compliance Analyst (BCA). The BCA has CPA credentials and a Master?s degree in accounting. The role of the BCA will include oversight of the Perkins Loan Program managed through the College. The BCA will provide analysis and assessment of outstanding Perkins loans to determine requirements for loan reassignment to the DOE. There were no questioned costs associated with the finding.
Show full finding ▾Hide full finding ▴ALN Number, Federal Agency, and Program Name - Department of Education - Federal Perkins Loan Program ALN 84.038 Federal Award Identification Number and Year - Unknown Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Institutions must maintain copies of master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Disbursement records, electronic authentication and signature records for loans made with an MPN must also be retained by the institution. Institutions are required to keep original paper promissory notes or original paper MPNs and repayment schedules in a locked, fireproof container. The original promissory notes and repayment schedules must be kept until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. When an institution uses a third party service provider for its Perkins Loan program, the institution must perform due diligence to ensure that the third party is in compliance with the requirements for the functions the third party service provider is performing for the school. Such due diligence could include obtaining and reviewing the third party's most recent Title IV compliance audit. (34 CFR 674.19.(e).) Condition - Of the 25 students tested, 1 student was identified to not have a master promissory note on file. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where the University and its third party loan service provider, ECSI, could not locate the master promissory note for a student. Cause and Effect - The University did not have an effective control in place to ensure that all open Perkins loan master promissory notes are kept. Recommendation - The University should implement controls to ensure Perkins master promissory notes are retained. Views of Responsible Officials and Corrective Action Plan - The College hired a new senior level Business & Compliance Analyst (BCA). The BCA has CPA credentials and a Master?s degree in accounting. The role of the BCA will include oversight of the Perkins Loan Program managed through the College. The BCA will provide analysis and assessment of outstanding Perkins loans to determine requirements for loan reassignment to the DOE. There were no questioned costs associated with the finding.
Finding Number: 2021-003 Condition: Of the 25 students tested, 1 student was identified to not have a master promissory note on file. Planned Corrective Action: The College hired a new senior level Business & Compliance Analyst (BCA). The BCA has CPA credentials and a Master?s degree in accounting. The role of the BCA will include oversight of the Perkins Loan Program managed through the College. The BCA will provide analysis and assessment of outstanding Perkins loans to determine requirements for loan reassignment to the DOE. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Jerry L. Wright VP Business Affairs/CFO Anticipated Completion Date: 03-01-2022
ALN Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 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. (34 CFR 668.173(b); 34 CFR Section 668.22(j)). Condition - Of the 9 students selected for return to Title IV testing, the University did not return the funds of 1 student within 45 days of becoming aware that the student had withdrawn from classes. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where a student withdrew from all eligible credit courses in the fall semester of 2020 but did not have a return of Title IV refund calculation performed within the required time frame. This was due to the registrar's office failing to notify student financial aid. Cause and Effect - The University did not have the proper control in place to ensure students who withdraw from all eligible credit courses but remain in a non credit eligible course have a return to Title IV refund calculation performed in a timely manner. Recommendation - The University should consider implementing review procedures to verify that all students needing calculations have been identified. Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan already implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President?s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the ?Adrian College Data Integrity Notification Guidelines? policy document). Assessment will be periodically evaluated via the College?s internal audit process. Note: All Title IV funds were fully returned by the College as required.
Show full finding ▾Hide full finding ▴ALN Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - 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. (34 CFR 668.173(b); 34 CFR Section 668.22(j)). Condition - Of the 9 students selected for return to Title IV testing, the University did not return the funds of 1 student within 45 days of becoming aware that the student had withdrawn from classes. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There was one instance identified where a student withdrew from all eligible credit courses in the fall semester of 2020 but did not have a return of Title IV refund calculation performed within the required time frame. This was due to the registrar's office failing to notify student financial aid. Cause and Effect - The University did not have the proper control in place to ensure students who withdraw from all eligible credit courses but remain in a non credit eligible course have a return to Title IV refund calculation performed in a timely manner. Recommendation - The University should consider implementing review procedures to verify that all students needing calculations have been identified. Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan already implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President?s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the ?Adrian College Data Integrity Notification Guidelines? policy document). Assessment will be periodically evaluated via the College?s internal audit process. Note: All Title IV funds were fully returned by the College as required.
Finding Number: 2021-004 Condition: Of the 9 students selected for return to Title IV testing, the College did not return the funds of 1 student within 45 days of becoming aware that the student had withdrawn from classes. Planned Corrective Action: The College corrective action plan already implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President?s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the ?Adrian College Data Integrity Notification Guidelines? policy document). Assessment will be periodically evaluated via the College?s internal audit process. Note: All Title-IV funds were fully returned by the College as required. Contact person responsible for corrective action: Andrea Milner VP Academic Affairs/Dean Anticipated Completion Date: 10-01-2021
ALN Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans Pass through Entity - N/A- Direct Award Finding Type - Significant deficiency Repeat Finding - Yes 2020-003, 2019-002, 2018-002, 2017-001 Criteria - Under the Federal Direct Student Loan Program (34 CFR Section 685.309(b)) and Federal Pell Grant Program (34 CFR Section 690.83(b)(2)), schools must complete and return within 30 days of receipt the student status confirmation reports. The College must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Condition - Of the 40 students tested, 1 student was identified that did not have their student status confirmation report sent to NSLDS within the 60 day requirement. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The enrollment status change was not reported for 1 student out of our sample of 40. Cause and Effect - Prior to the winter semester, the College did not have review procedures in place to properly ensure all students' statuses were updated in NSLDS properly and timely. This particular student was from the fall semester during the time frame that procedures were being improved at the College. Recommendation - The College should continue to improve their procedures relating to withdrawn and graduated students to ensure each student's status is updated in NSLDS properly and timely. Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan already implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President?s Office. This exercise followed the fiscal year 2020 audit report. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the ?Adrian College Data Integrity Notification Guidelines? policy document). Assessment will be periodically evaluated via the College?s internal audit process. Note: For the one student identified in the test sample with a past due reporting date, that deadline was missed by three days. Also, that occurrence was from the fall semester 2020 when the College was implementing revised reporting procedures. All other tested students were identified as meeting the reporting deadline requirements. There were no questioned costs associated with the finding.
Show full finding ▾Hide full finding ▴ALN Number, Federal Agency, and Program Name - Department of Education - Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063 Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans Pass through Entity - N/A- Direct Award Finding Type - Significant deficiency Repeat Finding - Yes 2020-003, 2019-002, 2018-002, 2017-001 Criteria - Under the Federal Direct Student Loan Program (34 CFR Section 685.309(b)) and Federal Pell Grant Program (34 CFR Section 690.83(b)(2)), schools must complete and return within 30 days of receipt the student status confirmation reports. The College must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Condition - Of the 40 students tested, 1 student was identified that did not have their student status confirmation report sent to NSLDS within the 60 day requirement. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The enrollment status change was not reported for 1 student out of our sample of 40. Cause and Effect - Prior to the winter semester, the College did not have review procedures in place to properly ensure all students' statuses were updated in NSLDS properly and timely. This particular student was from the fall semester during the time frame that procedures were being improved at the College. Recommendation - The College should continue to improve their procedures relating to withdrawn and graduated students to ensure each student's status is updated in NSLDS properly and timely. Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan already implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President?s Office. This exercise followed the fiscal year 2020 audit report. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the ?Adrian College Data Integrity Notification Guidelines? policy document). Assessment will be periodically evaluated via the College?s internal audit process. Note: For the one student identified in the test sample with a past due reporting date, that deadline was missed by three days. Also, that occurrence was from the fall semester 2020 when the College was implementing revised reporting procedures. All other tested students were identified as meeting the reporting deadline requirements. There were no questioned costs associated with the finding.
Finding Number: 2021-005 Condition: Of the 40 students tested, 1 student was identified that did not have their student status confirmation report sent to NSLDS within the 60 day requirement. Planned Corrective Action: The College corrective action plan already implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President?s Office. This exercise followed the fiscal year 2020 audit report. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the ?Adrian College Data Integrity Notification Guidelines? policy document). Assessment will be periodically evaluated via the College?s internal audit process. Note: For the one student identified in the test sample with a past due reporting date, that deadline was missed by three days. Also, that occurrence was from the fall semester 2020 when the College was implementing revised reporting procedures. All other tested students were identified as meeting the reporting deadline requirements. There were no questioned costs associated with the finding. Contact person responsible for corrective action: Andrea Milner VP Academic Affairs/Dean Anticipated Completion Date: 10-01-2021
2020-003
FAC accepted this audit on June 2, 2021 — management decision was due December 2, 2021.
CFDA Number, Federal Agency, and Program Name - Student Financial Aid Cluster (Federal Pell Grant Program 84.063, Federal Direct Student Loans 84.268) Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans, 2019 Pass through Entity - N/A - Direct award Finding Type - Material weakness Repeat Finding - Yes 2019 002, 2018 002, 2017 001 Criteria - Under the Federal Direct Student Loan Program (Direct Loan, 34 CFR Section 685.309) and Federal Pell Grant Program (Pell, 34 CFR Section 690.83(b)(2)), schools must complete and return within 30 days of receipt the student status confirmation reports. The College must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Condition - During testing, it was identified that the College did not appropriately update the status for certain students within the required 30 day time frame. Questioned Costs - N/A, no questioned costs Identification of How Questioned Costs Were Computed - N/A Context - The enrollment status change was not reported for 9 students (graduates) out of our sample of 40 (change was reported subsequent to testing). Additionally, the enrollment status change was reported beyond the required 30 day time frame for 11 students (withdrawn and graduates) out of our sample of 40. Cause and Effect - The College did not have review procedures in place to properly ensure all students' statuses were updated in NSLDS properly and timely. Recommendation - The College should implement a procedure to review the listing of withdrawn and graduated students to ensure each student's status is updated in NSLDS properly and timely. Views of Responsible Officials and Corrective Action Plan - IT will report enrollment status on a monthly basis for the entire student population that enrolls in fall and spring semesters and continue to report the enrollment status of this population of students until the next academic year begins.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - Student Financial Aid Cluster (Federal Pell Grant Program 84.063, Federal Direct Student Loans 84.268) Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans, 2019 Pass through Entity - N/A - Direct award Finding Type - Material weakness Repeat Finding - Yes 2019 002, 2018 002, 2017 001 Criteria - Under the Federal Direct Student Loan Program (Direct Loan, 34 CFR Section 685.309) and Federal Pell Grant Program (Pell, 34 CFR Section 690.83(b)(2)), schools must complete and return within 30 days of receipt the student status confirmation reports. The College must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. Condition - During testing, it was identified that the College did not appropriately update the status for certain students within the required 30 day time frame. Questioned Costs - N/A, no questioned costs Identification of How Questioned Costs Were Computed - N/A Context - The enrollment status change was not reported for 9 students (graduates) out of our sample of 40 (change was reported subsequent to testing). Additionally, the enrollment status change was reported beyond the required 30 day time frame for 11 students (withdrawn and graduates) out of our sample of 40. Cause and Effect - The College did not have review procedures in place to properly ensure all students' statuses were updated in NSLDS properly and timely. Recommendation - The College should implement a procedure to review the listing of withdrawn and graduated students to ensure each student's status is updated in NSLDS properly and timely. Views of Responsible Officials and Corrective Action Plan - IT will report enrollment status on a monthly basis for the entire student population that enrolls in fall and spring semesters and continue to report the enrollment status of this population of students until the next academic year begins.
Finding Number: 2020-003 Condition: Of the 40 students selected for status change testing, 9 of those students did not have a status change reported and 1O additional students did not have their status change reported in a timely manner. Planned Corrective Action: Adrian College is implementing a new comprehensive Student Information System (SIS) with an anticipated "go live" date of 1-July-2021. Within this SIS will be a standard report generator that will produce periodic degree conferral status update reports. Such reports will be regularly reviewed for compliance with National Student Clearing House reporting standards, including timeliness of reporting. Contact person responsible for corrective action: Dan Thompson - Student Information System Data Administrator Kristina Schweikert - Registrar Anticipated Completion Date: 1-July-2021
2019-002
FAC accepted this audit on March 29, 2020 — management decision was due September 29, 2020.
CFDA Number, Federal Agency, and Program Name - Student Financial Aid Cluster (Federal Pell Grant Program - 84.063, Federal Direct Student Loans - 84.268), Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans, 2019, Pass-through Entity - N/A - Direct Award, Finding Type - Significant deficiency, Repeat Finding - Yes, Criteria - Under the Direct Loan programs (Direct Loan, 34 CFR Section 685.309), schools must complete and return within 30 days of receipt the student status confirmation reports. The institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website., Condition - During testing, it was identified that the College did not appropriately update the status for certain students within the required 30-day time frame., Questioned Costs - N/A, no questioned costs, Identification of How Questioned Costs Were Computed - N/A, Context - The enrollment status change was not appropriately reported for 16 students (graduates) out of our sample of 40. Additionally, the enrollment status change was reported beyond the required 30-day time frame for 10 students (withdrawn and graduates) out of our sample of 40., Cause and Effect - The College did not have review procedures in place to properly ensure all students' statuses were updated in NSLDS properly and timely., Recommendation - The College should implement a procedure to review the listing of withdrawn and graduated students to ensure each student's status is updated in NSLDS properly and timely., Views of Responsible Officials and Corrective Action Plan - IT will report enrollment status on a monthly basis for the entire student population that enrolls in fall and spring semesters and continue to report the enrollment status of this population of students until the next academic year begins.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - Student Financial Aid Cluster (Federal Pell Grant Program - 84.063, Federal Direct Student Loans - 84.268), Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans, 2019, Pass-through Entity - N/A - Direct Award, Finding Type - Significant deficiency, Repeat Finding - Yes, Criteria - Under the Direct Loan programs (Direct Loan, 34 CFR Section 685.309), schools must complete and return within 30 days of receipt the student status confirmation reports. The institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website., Condition - During testing, it was identified that the College did not appropriately update the status for certain students within the required 30-day time frame., Questioned Costs - N/A, no questioned costs, Identification of How Questioned Costs Were Computed - N/A, Context - The enrollment status change was not appropriately reported for 16 students (graduates) out of our sample of 40. Additionally, the enrollment status change was reported beyond the required 30-day time frame for 10 students (withdrawn and graduates) out of our sample of 40., Cause and Effect - The College did not have review procedures in place to properly ensure all students' statuses were updated in NSLDS properly and timely., Recommendation - The College should implement a procedure to review the listing of withdrawn and graduated students to ensure each student's status is updated in NSLDS properly and timely., Views of Responsible Officials and Corrective Action Plan - IT will report enrollment status on a monthly basis for the entire student population that enrolls in fall and spring semesters and continue to report the enrollment status of this population of students until the next academic year begins.
Finding Number: 2019-002 Condition: During testing, it was identified that the College did not appropriately update the status for certain students within the required 30-day time frame. Planned Corrective Action: IT will report enrollment status on a monthly basis for the entire student population that enrolls fall/spring semester and continue to report the enrollment status of this population of students until the next academic year begins. Contact person responsible for corrective action: Stephen Buckland Anticipated Completion Date: 06/30/2020
2018-002
CFDA Number, Federal Agency, and Program Name - Student Financial Aid Cluster (Federal Pell Grant Program - 84.063, Federal Direct Student Loans - 84.268), Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans, 2019, Pass-through Entity - N/A - Direct Award, Finding Type - Significant deficiency, Repeat Finding - No, Criteria - The College is required by 34 CFR 668.165(a) to notify students of the amount of funds that the student or his or her parent can expect to receive, how and when those funds will be disbursed, and the student's or parent's right to refuse the loans., Condition - The College did not notify certain students receiving direct loans of the amount of funds to expect, how and when the funds would be disbursed, and the student's right to refuse the loans., Questioned Costs - N/A, no questioned costs., Identification of How Questioned Costs Were Computed - N/A, Context - Of the 25 students selected for eligibility and disbursement testing, two of those students did not receive a notification letter for disbursements that occurred in the middle of the semester., Cause and Effect - The College did not have the additional disbursements properly coded within the financial aid system and a notification letter was not generated., Recommendation - The College should implement a procedure to ensure all required communication is completed., Views of Responsible Officials and Planned Corrective Actions - If the Financial Aid department receives a request to increase the amount of a Federal Direct Loan after the initial amount awarded has been originated and disbursed, they will do one of two things: 1) create a new award reflecting the increased loan amount. Creating a new award will ensure that disbursement notification reflecting the net amount of the increase is caught and sent by our system. 2) Manually schedule PowerFAIDS to resend disbursement notification to the student that received a loan increase.
Show full finding ▾Hide full finding ▴CFDA Number, Federal Agency, and Program Name - Student Financial Aid Cluster (Federal Pell Grant Program - 84.063, Federal Direct Student Loans - 84.268), Federal Award Identification Number and Year - Federal Pell Grant Program, Federal Direct Student Loans, 2019, Pass-through Entity - N/A - Direct Award, Finding Type - Significant deficiency, Repeat Finding - No, Criteria - The College is required by 34 CFR 668.165(a) to notify students of the amount of funds that the student or his or her parent can expect to receive, how and when those funds will be disbursed, and the student's or parent's right to refuse the loans., Condition - The College did not notify certain students receiving direct loans of the amount of funds to expect, how and when the funds would be disbursed, and the student's right to refuse the loans., Questioned Costs - N/A, no questioned costs., Identification of How Questioned Costs Were Computed - N/A, Context - Of the 25 students selected for eligibility and disbursement testing, two of those students did not receive a notification letter for disbursements that occurred in the middle of the semester., Cause and Effect - The College did not have the additional disbursements properly coded within the financial aid system and a notification letter was not generated., Recommendation - The College should implement a procedure to ensure all required communication is completed., Views of Responsible Officials and Planned Corrective Actions - If the Financial Aid department receives a request to increase the amount of a Federal Direct Loan after the initial amount awarded has been originated and disbursed, they will do one of two things: 1) create a new award reflecting the increased loan amount. Creating a new award will ensure that disbursement notification reflecting the net amount of the increase is caught and sent by our system. 2) Manually schedule PowerFAIDS to resend disbursement notification to the student that received a loan increase.
Finding Number: 2019-003 Condition: The College did not notify certain students receiving direct student loans of the amount of funds to expect, how and when the funds would be disbursed, and the student?s right to refuse the loans. Planned Corrective Action: If we receive a request to increase the amount of a Federal Direct Loan after the initial amount awarded has been originated and disbursed, we will do one of two things; 1) create a new award reflecting the increased loan amount. Creating a new award will ensure that disbursement notification reflecting the net amount of the increase is caught and sent by our system. 2) Manually schedule PowerFAIDS to resend disbursement notification to the student that received a loan increase. Contact person responsible for corrective action: Stephen Buckland Anticipated Completion Date: 06/30/2020
FAC accepted this audit on March 3, 2019 — management decision was due September 3, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on February 14, 2018 — management decision was due August 14, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
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