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MID MICHIGAN COLLEGEHigher Education

EIN: 381812272

UEI: XCZ9Q91GKCS6

Audited by: REHMANN ROBSON LLC

Oversight agency: 84 [Department of Education]

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Data as of September 2, 2026

MID MICHIGAN COLLEGE10 audit years10 findings4 repeat
10
Audit Years
10
Total Findings
4
Repeat Findings
$13.5M
Federal Awards Expended (FY 2025)

FY 2025-06-30

LOW-RISK AUDITEE$13,457,839 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on January 6, 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 July 6, 2026 (62 days ago).

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2025-001
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242047, P033A242047, P063P242848, and P268K252848. Criteria. The total aid awarded is not to exceed the student's financial need or cost, as specified by the 34 CFR 668.42 (FWS), 34 CFR 673.5 and 673.6 (FSEOG); and 34 CFR 685.301 (Direct Loan). Condition. During our cost of attendance recalculation, we noted that for one student, an additional semester in which the student was not taking any classes was included in their calculation. Cause. The College does not have a review process in place for ensuring the manual inputs used in the cost of attendance determination are accurate. Effect. As a result of this condition, the College overstated the student's financial need for the award year. However, no action was required by the College as the corrected cost of attendance still exceeded the student's awards. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

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Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A242047, P033A242047, P063P242848, and P268K252848. Criteria. The total aid awarded is not to exceed the student's financial need or cost, as specified by the 34 CFR 668.42 (FWS), 34 CFR 673.5 and 673.6 (FSEOG); and 34 CFR 685.301 (Direct Loan). Condition. During our cost of attendance recalculation, we noted that for one student, an additional semester in which the student was not taking any classes was included in their calculation. Cause. The College does not have a review process in place for ensuring the manual inputs used in the cost of attendance determination are accurate. Effect. As a result of this condition, the College overstated the student's financial need for the award year. However, no action was required by the College as the corrected cost of attendance still exceeded the student's awards. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Auditor Description of Condition and Effect. During our cost of attendance recalculation, we noted that for one student, an additional semester in which the student was not taking any classes was included in their calculation. As a result of this condition, the College overstated the student's financial need for the award year. However, no action was required by the College as the corrected cost of attendance still exceeded the student's awards. Auditor Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. Auditor Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. Corrective Action. Upon discovery of the cost of attendance calculation error, the College went through and determined that this was an isolated incident and had no impact on the amount of aid received by the student. To prevent a similar problem arising in the future, the College will implement a review process to have a second individual review and ensure the cost of attendance is being calculated accurately. Responsible Person. Michelle McNier, Director of Financial Aid. Anticipated Completion Date. June 30, 2026.

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FY 2024-06-30

LOW-RISK AUDITEE$13,437,336 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 7, 2025 — management decision was due August 7, 2025.

FY 2023-06-30

LOW-RISK AUDITEE$14,094,925 federal awards expended

FAC accepted this audit on January 15, 2024 — management decision was due July 15, 2024.

2023-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268; Award Numbers P007A222047, P033A222047, P063P222848, P268K232848. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information-sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the assessment of apps that are developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in accordance with the Gramm Leach Bliley Policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

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Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268; Award Numbers P007A222047, P033A222047, P063P222848, P268K232848. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information-sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the assessment of apps that are developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in accordance with the Gramm Leach Bliley Policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.

Corrective Action Plan

Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the assessment of apps that are developed by the institution. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Auditor Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. Corrective Action. Currently, the College is reviewing the compliance requirements for Gramm Leach Bliley and will amend the current policy to ensure the assessment of apps developed by the institution is covered within the policy. Responsible Person. Kirk Lehr, Director of IT Anticipated Completion Date. June 30, 2024

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FY 2022-06-30

$18,842,470 federal awards expended

FAC accepted this audit on March 1, 2023 — management decision was due September 1, 2023.

2022-001
Special Tests & Provisions
REPEAT OF 2021-001OTHER MATTERS

2022-001 - Timeliness of Student Status Changes (Repeat Finding) Finding Type. Immaterial Noncompliance Program. Student Financial Assistance Cluster; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants ("FSEOG"), Assistance Listing Number 84.007, Award Number P007A212047; Federal Work Study ("FWS"), Assistance Listing Number 84.033, Award Number P033A212047; Federal Pell Grant Program, Assistance Listing Number 84.063, Award Number P063P212848; and Federal Direct Student Loans Program, Assistance Listing Number 84.268, Award Number P268K212848. Criteria. The Compliance Supplement states that a College must report student status changes within 60 days of the status change. Condition. A status change was not updated for one of the forty students selected for testing who unofficially withdrew during the fiscal year. Cause. A status change was not updated for one of the students selected for testing who withdrew during the year. The College had a process in place to identify incorrectly submitted withdrawal statuses or dates to National Student Loan Data System (NSLDS), however, this process was not fully followed by an employee who is no longer employed at the College. Effect. As a result of this condition, the College did not fully comply with the requirements to report all student status changes and as a result of this condition, the College was exposed to not consistently reporting all student status changes correctly. Questioned Costs. No costs were required to be questioned as a result of this finding. Recommendation. We recommend that the College follow implemented procedures to include all status changes when reporting status changes to the NSLDS. View of Responsible Officials. Management believes this was an isolated incident and was identified internally during the fiscal year. Subsequent to this issue being found, the College engaged their IT department to look further into the cause of why some students were being reported with wrong dates. The College ended up changing how the Colleague-generated report that is sent to the Clearinghouse pulls withdrawn students so as to ensure these issues occur less often. The College believes that the corrective actions they have taken will be sufficient.

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2022-001 - Timeliness of Student Status Changes (Repeat Finding) Finding Type. Immaterial Noncompliance Program. Student Financial Assistance Cluster; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants ("FSEOG"), Assistance Listing Number 84.007, Award Number P007A212047; Federal Work Study ("FWS"), Assistance Listing Number 84.033, Award Number P033A212047; Federal Pell Grant Program, Assistance Listing Number 84.063, Award Number P063P212848; and Federal Direct Student Loans Program, Assistance Listing Number 84.268, Award Number P268K212848. Criteria. The Compliance Supplement states that a College must report student status changes within 60 days of the status change. Condition. A status change was not updated for one of the forty students selected for testing who unofficially withdrew during the fiscal year. Cause. A status change was not updated for one of the students selected for testing who withdrew during the year. The College had a process in place to identify incorrectly submitted withdrawal statuses or dates to National Student Loan Data System (NSLDS), however, this process was not fully followed by an employee who is no longer employed at the College. Effect. As a result of this condition, the College did not fully comply with the requirements to report all student status changes and as a result of this condition, the College was exposed to not consistently reporting all student status changes correctly. Questioned Costs. No costs were required to be questioned as a result of this finding. Recommendation. We recommend that the College follow implemented procedures to include all status changes when reporting status changes to the NSLDS. View of Responsible Officials. Management believes this was an isolated incident and was identified internally during the fiscal year. Subsequent to this issue being found, the College engaged their IT department to look further into the cause of why some students were being reported with wrong dates. The College ended up changing how the Colleague-generated report that is sent to the Clearinghouse pulls withdrawn students so as to ensure these issues occur less often. The College believes that the corrective actions they have taken will be sufficient.

Corrective Action Plan

CORRECTIVE ACTION PLAN The compliance audit identified one finding, which is described in the Schedule of Findings and Questioned Costs. We evaluated this matter, as described below, and have outlined our corrective actions as a result. 2022-001 - Timeliness of Student Status Changes Background Gabrielle Coles was found to be reported to NSLDS for enrollment status change 9 days late, on the 69th day. This student officially withdrew from the Fall 2021 semester on November 30, 2021. At the time of the fall withdrawal, the student was also registered for winter term at half time. The original setup of the Colleague system caused the incorrect enrollment status to be reported for the student (as it was not considering the use of the unofficial withdrawal date in the Clearinghouse report file). However, we do have measures in place to review our withdrawn students one by one out in NSLDS to ensure we are compliant. When it was found by the Financial Aid Specialist that an error was reported to NSLDS, the responsible party -the former Registrar- was notified on two separate occasions to have the status updated; both notifications happened prior to the 60-day mark. Despite the notifications, the error was not updated until the 69th day. Issue The Colleague system did not correctly pull the withdrawal status or correct date. However, the issue was found well before the 60-day mark by the Financial Aid Specialist who reviews each withdrawn student in NSLDS biweekly. The Specialist did notify the responsible party of the error (twice). Due to human error (as we believe the former Registrar did not notice the fall withdrawal but instead only saw the half time winter registration), the issue was not resolved in time. This individual no longer works at the college. Subsequent to this issue, IT was engaged to look further into the Colleague report to identify the root cause of why some students were being reported with the wrong dates. After much research, we changed how the report was pulling withdrawn students and their withdrawal date. This change will also prevent issues from occurring in the future. Resolution With the corrective action plan put in place of both the Colleague system considering the unofficial date of withdrawal and the Financial Aid Specialist notifying the responsible party of enrollment status changes that are incorrect at NSLDS, we are confident that the enrollment reporting requirements should now be met. Responsible Party Director of Financial Aid ? Sarah Kasabian-Larson Date of Planned Corrective Action Effective immediately. March 2nd, 2022 Management Assessment We concur with the audit assessment regarding this matter.

Prior Finding References

2021-001

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FY 2021-06-30

$17,255,812 federal awards expended

FAC accepted this audit on March 27, 2022 — management decision was due September 27, 2022.

2021-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2020-001OTHER MATTERS

2021-001 - Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants ("FSEOG"), Assistance Listing Number 84.007, Award Number P007A202047; Federal Work Study ("FWS"), Assistance Listing Number 84.033, Award Number P033A202047; Federal Pell Grant Program, Assistance Listing Number 84.063, Award Number P063P202848; and Federal Direct Student Loans Program, Assistance Listing Number 84.268, Award Number P268K212848. Criteria. The Compliance Supplement states that a College must report student status changes within 60 days of the status change. Condition. A status change was not updated for one of the forty students selected for testing who unofficially withdrew during the fiscal year. Cause. The student was registered as full-time, with one class being a module course which only ran the first eight weeks of the semester. The student completed the module course but unofficially withdrew from all remaining courses in the semester. The College's system did not recognize this student as unofficially withdrawn, due to the completion of the module class. Effect. As a result of this condition, the College did not fully comply with the requirements to report all student status changes and as a result of this condition, the College was exposed to not consistently reporting all student status changes correctly. Questioned Costs. No costs were required to be questioned as a result of this finding. Recommendation. We recommend that the College implement procedures to include all status changes when reporting status changes to the National Student Loan Data System. View of Responsible Officials. Management believes this was an isolated incident and has prepared a Corrective Action Plan.

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2021-001 - Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants ("FSEOG"), Assistance Listing Number 84.007, Award Number P007A202047; Federal Work Study ("FWS"), Assistance Listing Number 84.033, Award Number P033A202047; Federal Pell Grant Program, Assistance Listing Number 84.063, Award Number P063P202848; and Federal Direct Student Loans Program, Assistance Listing Number 84.268, Award Number P268K212848. Criteria. The Compliance Supplement states that a College must report student status changes within 60 days of the status change. Condition. A status change was not updated for one of the forty students selected for testing who unofficially withdrew during the fiscal year. Cause. The student was registered as full-time, with one class being a module course which only ran the first eight weeks of the semester. The student completed the module course but unofficially withdrew from all remaining courses in the semester. The College's system did not recognize this student as unofficially withdrawn, due to the completion of the module class. Effect. As a result of this condition, the College did not fully comply with the requirements to report all student status changes and as a result of this condition, the College was exposed to not consistently reporting all student status changes correctly. Questioned Costs. No costs were required to be questioned as a result of this finding. Recommendation. We recommend that the College implement procedures to include all status changes when reporting status changes to the National Student Loan Data System. View of Responsible Officials. Management believes this was an isolated incident and has prepared a Corrective Action Plan.

Corrective Action Plan

CORRECTIVE ACTION PLAN The compliance audit identified one finding, which is described in the Schedule of Findings and Questioned Costs. We evaluated this matter, as described below, and have outlined our corrective actions as a result. 2021-001 - Timeliness of Student Status Changes Background. The finding of the student status change is an isolated and very unique incident. The student began the Winter 2021 term as a full-time student. The student was registered for four classes; three classes were 16-week courses, and one course was a first eight-week course. The student completed the first eight-week course, earning a D grade. The student then stopped attending the other three courses, at different times, but was not an official withdrawal. After the term concluded, an unofficial withdrawal was completed. See the single audit report for the last dates of attendance for the three 16-week courses that the student did not complete. Issue. Due to the student completing the first eight-week module course and earning a D grade, but ceasing enrollment thereafter, the system did not recognize the student had withdrawn (unofficial). Consequently, the system continued to report the student as full time. To explain further, the system saw that this student earned a grade in the semester and saw it as essentially a student that finished the term. This is not accurate as the student stopped attending completely as of March 26, 2021. Return of funds was calculated at the end of the term correctly (as this is reviewed manually), however, the system reported to the Clearinghouse incorrect information. Planned Corrective Action. Currently, the College is reviewing how the system views module courses and how that plays into the withdrawal (official and unofficial) process. A change to the system report has been identified that may switch a student in this unique situation to withdrawn appropriately; further testing is currently being done to verify this change. In the meantime, when a very unique situation such as this occurs, where a student completes a first eight-week course but subsequently ceases enrollment and is found during the return of funds process, Financial Aid will make a manual update to Clearinghouse and notification will be sent to the Registrar to make sure reporting is correct. Responsible Party. Sarah Kasabian-Larson, Director of Financial Aid. Date of Planned Corrective Action. Effective immediately - March 2nd, 2022. Management Assessment. We concur with the audit assessment regarding this matter.

Prior Finding References

2020-001

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FY 2020-06-30

$14,188,531 federal awards expended

FAC accepted this audit on December 2, 2020 — management decision was due June 2, 2021.

2020-001
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2019-002OTHER MATTERS

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster, U.S. Department of Education, Federal Direct Loan Program (84.268) Federal Award Identification Number and Year - NA Pass-through Entity - NA Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2019-002 Criteria Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition The College did not report certain student status changes in a timely manner. Questioned Costs None Context Of the 40 students selected for status change testing, 1 student did not have a status change reported in a timely manner. Cause and Effect A control was not in place to ensure the College's graduation report was complete. As a result, certain graduates' status was not updated timely. Recommendation We recommend the College review the process and controls over the graduation and withdrawal report completeness. Views of Responsible Officials and Corrective Action Plan During the 2019 2020 audit, one student from the 2018 2019 academic year was discovered to have their graduation date reported past the required deadline. The corrective action from the 2018 2019 audit was added to the double check process and fully implemented in 2019 2020. However, because the 2019 2020 audit included a student from the 2018 2019 academic year, this student?s record was not part of the fully implemented 2019 2020 process, and the error pertaining to the 2018 2019 academic year was not detected in a timely manner. The corrective action plan from the 2018 2019 audit, fully implemented in 2019 2020, has resolved this issue from recurring.

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CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster, U.S. Department of Education, Federal Direct Loan Program (84.268) Federal Award Identification Number and Year - NA Pass-through Entity - NA Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2019-002 Criteria Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition The College did not report certain student status changes in a timely manner. Questioned Costs None Context Of the 40 students selected for status change testing, 1 student did not have a status change reported in a timely manner. Cause and Effect A control was not in place to ensure the College's graduation report was complete. As a result, certain graduates' status was not updated timely. Recommendation We recommend the College review the process and controls over the graduation and withdrawal report completeness. Views of Responsible Officials and Corrective Action Plan During the 2019 2020 audit, one student from the 2018 2019 academic year was discovered to have their graduation date reported past the required deadline. The corrective action from the 2018 2019 audit was added to the double check process and fully implemented in 2019 2020. However, because the 2019 2020 audit included a student from the 2018 2019 academic year, this student?s record was not part of the fully implemented 2019 2020 process, and the error pertaining to the 2018 2019 academic year was not detected in a timely manner. The corrective action plan from the 2018 2019 audit, fully implemented in 2019 2020, has resolved this issue from recurring.

Corrective Action Plan

Finding Number: 2020-001 Condition: The College did not report certain student status changes in a timely manner. Planned Corrective Action: During the 2019-2020 audit, one student from the 2018-2019 academic year was discovered to have their graduation date reported past the required deadline. The corrective action from the 2018-2019 audit was added to the double-check process and fully implemented in 2019- 2020. However, because the 2019-2020 audit included a student from the 2018-2019 academic year, this student?s record was not part of the fully implemented 2019-2020 process and the error pertaining to the 2018-2019 academic year was not detected in a timely manner. The corrective action plan from the 2018-2019 audit, fully implemented in 2019-2020, has resolved this issue from recurring. Contact person responsible for corrective action: Anita West, Director of Financial Aid Anticipated Completion Date: The 2018-2019 Corrective Action Plan was implemented beginning with the 2019-2020 academic year.

Prior Finding References

2019-002

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2020-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster, U.S. Department of Education, Federal Direct Loan Program (84.268) Federal Award Identification Number and Year - NA Pass-through Entity - NA Finding Type - Significant deficiency Repeat Finding - No Criteria The College must notify a student of the amount of loan funds that the student or his or her parent can expect to receive, which funds are from subsidized loans and which are from unsubsidized loans, and how and when those funds will be disbursed. The notification should also include the date and amount of the disbursement, and the student?s right or parent?s right to cancel all or a portion of that loan disbursement. The College must send the notification in writing within 30 days prior to or after crediting the student?s account at the institution (34 CFR Section 668.165(a)(2) and 34 CFR Section 668.165(a)(3)). Condition The College did not provide adequate notification of loan disbursements and the right to cancel all or a portion of the loans to students or parents. Questioned Costs None Context Of the 23 students selected for notification testing, 1 of these students did not receive notification in a timely manner. Cause and Effect Due to the disruption of college operations as a result of the COVID 19 pandemic, a student did not receive timely notification. Recommendation The College should implement a process to ensure all students or parents of loan disbursements receive timely notification. Views of Responsible Officials and Planned Corrective Actions During the College's closure due to COVID 19, the associate director of financial aid (AD) took over from financial aid analyst (FAA) performance of the pretransmittal process during the month of April. This was during a period of time where remote work was required, and the FAA who performed the pretransmittal process had unreliable internet service for conducting critical processing remotely. (The FAA was deemed an essential worker in May 2020 and resumed pretransmittal processing on campus.) There was a step left off of the financial aid office processing calendar (though it was on the FAA?s personal calendar) that served as a reminder to send out EFT emails to students regarding their loans (as described in the finding) as part of the pretransmittal process. Therefore, during the period of time that AD did the pretransmittal process for FAA, she did not do the EFT emails, as she was following process reminders from the financial aid processing calendar. We resolved this situation by adding the reminder to the processing calendar, and the student services specialist is now the individual responsible for performing the process that sends the EFT email notifications on a weekly basis. FAA is backup support for processing the email notifications.

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CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster, U.S. Department of Education, Federal Direct Loan Program (84.268) Federal Award Identification Number and Year - NA Pass-through Entity - NA Finding Type - Significant deficiency Repeat Finding - No Criteria The College must notify a student of the amount of loan funds that the student or his or her parent can expect to receive, which funds are from subsidized loans and which are from unsubsidized loans, and how and when those funds will be disbursed. The notification should also include the date and amount of the disbursement, and the student?s right or parent?s right to cancel all or a portion of that loan disbursement. The College must send the notification in writing within 30 days prior to or after crediting the student?s account at the institution (34 CFR Section 668.165(a)(2) and 34 CFR Section 668.165(a)(3)). Condition The College did not provide adequate notification of loan disbursements and the right to cancel all or a portion of the loans to students or parents. Questioned Costs None Context Of the 23 students selected for notification testing, 1 of these students did not receive notification in a timely manner. Cause and Effect Due to the disruption of college operations as a result of the COVID 19 pandemic, a student did not receive timely notification. Recommendation The College should implement a process to ensure all students or parents of loan disbursements receive timely notification. Views of Responsible Officials and Planned Corrective Actions During the College's closure due to COVID 19, the associate director of financial aid (AD) took over from financial aid analyst (FAA) performance of the pretransmittal process during the month of April. This was during a period of time where remote work was required, and the FAA who performed the pretransmittal process had unreliable internet service for conducting critical processing remotely. (The FAA was deemed an essential worker in May 2020 and resumed pretransmittal processing on campus.) There was a step left off of the financial aid office processing calendar (though it was on the FAA?s personal calendar) that served as a reminder to send out EFT emails to students regarding their loans (as described in the finding) as part of the pretransmittal process. Therefore, during the period of time that AD did the pretransmittal process for FAA, she did not do the EFT emails, as she was following process reminders from the financial aid processing calendar. We resolved this situation by adding the reminder to the processing calendar, and the student services specialist is now the individual responsible for performing the process that sends the EFT email notifications on a weekly basis. FAA is backup support for processing the email notifications.

Corrective Action Plan

Finding Number: 2020-002 Condition: The College did not provide adequate notification of loan disbursements and the right to cancel all or a portion of the loans to students or parents. Planned Corrective Action: During the College's closure due to COVID-19, the Associate Director of Financial Aid (AD) took over from Financial Aid Analyst (FAA) performance of the pre-transmittal process during the month of April. This was during a period of time where remote work was required, and the FAA who performed the pre-transmittal process had unreliable internet service for conducting critical processing remotely. (The FAA was deemed an essential worker in May 2020 and resumed pre-transmittal processing on campus.) There was a step left off of the Financial Aid Office Processing Calendar (though it was on the FAA?s personal calendar) that served as a reminder to send out EFT Emails to students regarding their loans (as described in the finding) as part of the pre- transmittal process. Therefore during the period of time that AD did the pre-transmittal process for FAA, she did not do the EFT Emails, as she was following process reminders from the Financial Aid Processing Calendar. We resolved this situation by adding the reminder to the Processing Calendar, and Student Services Specialist is now the individual responsible for performing the process that sends the EFT email notifications on a weekly basis. FAA is back-up support for processing the email notifications. Contact person responsible for corrective action: Anita West, Director of Financial Aid Anticipated Completion Date: This corrective action was implemented in July 2020.

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2020-003
Cash Management
SIGNIFICANT DEFICIENCY

CFDA Number, Federal Agency, and Program Name - 84.425, U.S. Department of Higher Education, Higher Education Emergency Relief Funds (HEERF) Federal Award Identification Number and Year - NA Pass-through Entity - NA Finding Type - Significant deficiency Repeat Finding - No Criteria The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. 2 CFR Section 200.305(b) Condition The College drew down all of the student grant portion of the HEERF funds allowed without minimizing the time between the transfer of funds and the disbursement of those funds. Questioned Costs None Context The College drew down $1,320,530 despite only expending $389,500 of these student grant funds as of June 30, 2020. Cause and Effect The College was not aware of the cash management requirements under the Uniform Guidance, which resulted in an excess of funds drawn down. Recommendation We recommend the College implement a process to ensure that the College minimizes the time elapsing between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Planned Corrective Actions We discovered guidance in early October 2020 that stated 2 CFR ? 200.305(b) of the Uniform Guidance applies to the HEERF funds. Following this guidance, we returned unspent funds via the G5 application and will redraw the funds as we disburse them, just as we do other grants.

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CFDA Number, Federal Agency, and Program Name - 84.425, U.S. Department of Higher Education, Higher Education Emergency Relief Funds (HEERF) Federal Award Identification Number and Year - NA Pass-through Entity - NA Finding Type - Significant deficiency Repeat Finding - No Criteria The College must minimize the time elapsing between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. 2 CFR Section 200.305(b) Condition The College drew down all of the student grant portion of the HEERF funds allowed without minimizing the time between the transfer of funds and the disbursement of those funds. Questioned Costs None Context The College drew down $1,320,530 despite only expending $389,500 of these student grant funds as of June 30, 2020. Cause and Effect The College was not aware of the cash management requirements under the Uniform Guidance, which resulted in an excess of funds drawn down. Recommendation We recommend the College implement a process to ensure that the College minimizes the time elapsing between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Planned Corrective Actions We discovered guidance in early October 2020 that stated 2 CFR ? 200.305(b) of the Uniform Guidance applies to the HEERF funds. Following this guidance, we returned unspent funds via the G5 application and will redraw the funds as we disburse them, just as we do other grants.

Corrective Action Plan

Finding Number: 2020-003 Condition: The College drew down all of the student portion of the HEERF funds allowed without minimizing the time between the transfer of funds and the disbursement of those funds. Planned Corrective Action: We discovered in early October that 2 CFR ? 200.305(b) of the Uniform Guidance applies to the HEERF funds. Following this guidance, we returned unspent funds via the G5 application and will re-draw the funds as we disburse them, just as we do other grants. Contact person responsible for corrective action: Susan Call Anticipated Completion Date: 10/13/2020

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FY 2019-06-30

$14,309,323 federal awards expended

FAC accepted this audit on November 11, 2019 — management decision was due May 11, 2020.

2019-002
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2018-002OTHER MATTERS

Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The College did not report certain student status changes in a timely manner. Questioned Costs - None Context - Of the 40 students selected for status change testing, 2 of these students did not have a status change reported in a timely manner. Cause and Effect - A control was not in place to ensure the College's graduation report was complete. As a result, certain graduates' status was not updated timely. Recommendation - We recommend the College review the process and controls over the graduation report completeness. Views of Responsible Officials and Corrective Action Plan - The College concurs and is implementing a process to review the graduation report for completeness.

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Criteria - Changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Condition - The College did not report certain student status changes in a timely manner. Questioned Costs - None Context - Of the 40 students selected for status change testing, 2 of these students did not have a status change reported in a timely manner. Cause and Effect - A control was not in place to ensure the College's graduation report was complete. As a result, certain graduates' status was not updated timely. Recommendation - We recommend the College review the process and controls over the graduation report completeness. Views of Responsible Officials and Corrective Action Plan - The College concurs and is implementing a process to review the graduation report for completeness.

Corrective Action Plan

Condition: The College did not report certain student status changes in a timely manner. Planned Corrective Action: Students who apply for graduation after the application deadline will not be backdated. Late requests for graduation will only be accepted within a week of the final day of the term. Any notifications or requests received after that date will be moved to the next graduation date. Additionally, after degrees are posted, graduates? files will be reviewed for any existing active programs. If existing programs are identified, the status will be changed to inactive. The College will limit students to one associate level program of study at a time. Contact person responsible for corrective action: Jennifer Cooper, Director of Student Financial Aid Anticipated Completion Date: 10/31/2019

Prior Finding References

2018-002

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FY 2018-06-30

$15,894,659 federal awards expended

FAC accepted this audit on November 1, 2018 — management decision was due May 1, 2019.

2018-002
Special Tests & Provisions
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-06-30

LOW-RISK AUDITEE$16,329,051 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 14, 2017 — management decision was due May 14, 2018.

FY 2016-06-30

LOW-RISK AUDITEE$17,051,904 federal awards expended

FAC accepted this audit on November 15, 2016 — management decision was due May 15, 2017.

2016-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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