EIN: 421027794
UEI: T7WMLBN6EJM3
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 11, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 11, 2026 (16 days from today).
What is a management decision? →The examination disclosed 5 students, out of 9 withdrawn student files tested, in which their Return of Title IV calculation was performed incorrectly. Student A – According to the R2T4 calculation the date of determination is 3/25/25 which is before the date of withdrawal of 4/10/25. No funding was effected. Student B – According to the R2T4 calculation the date of determination is 3/3/25 which is before the date of withdrawal of 3/31/25. The student was only eligible for 50% of their Title IV aid based on the College’s policies and procedures. The College should return $808 to Pell. Student C – According to the R2T4 calculation the date of determination is 2/20/25 which is before the date of withdrawal of 3/31/25. No funding was effected. Student D – According to the R2T4 calculation the date of determination is 3/11/25 which is before the date of withdrawal of 4/17/25. The student is only eligible for 50% of Title IV funds according to the College’s policies and procedures, $1,386.5 of Pell should be returned. Student E – According to the R2T4 calculation the date of determination is 2/20/25 which is before the date of withdrawal of 2/21/25. No funding was effected.
Show full finding ▾Hide full finding ▴The examination disclosed 5 students, out of 9 withdrawn student files tested, in which their Return of Title IV calculation was performed incorrectly. Student A – According to the R2T4 calculation the date of determination is 3/25/25 which is before the date of withdrawal of 4/10/25. No funding was effected. Student B – According to the R2T4 calculation the date of determination is 3/3/25 which is before the date of withdrawal of 3/31/25. The student was only eligible for 50% of their Title IV aid based on the College’s policies and procedures. The College should return $808 to Pell. Student C – According to the R2T4 calculation the date of determination is 2/20/25 which is before the date of withdrawal of 3/31/25. No funding was effected. Student D – According to the R2T4 calculation the date of determination is 3/11/25 which is before the date of withdrawal of 4/17/25. The student is only eligible for 50% of Title IV funds according to the College’s policies and procedures, $1,386.5 of Pell should be returned. Student E – According to the R2T4 calculation the date of determination is 2/20/25 which is before the date of withdrawal of 2/21/25. No funding was effected.
Corrective Action Plan for Current Year Findings 2025-001 Special Tests & Provisions – Return of Title IV Funds This Corrective Action Plan has been established by the Financial Aid and Registrar’s Offices to resolve findings related to Return of Title IV (R2T4) calculation errors. The goal of this plan is to ensure 100% data integrity through enhanced system logic, multi-tier manual verification, and cross-departmental reconciliation. Identify and Analyze Errors: The institution conducted a root-case analysis of the identified findings and determined the following: R2T4 Transposition Errors: For five (5) student records, the "Date of School’s Determination" (DOD) and the "Date of Withdrawal/Last Date of Engagement" (LDE) were inadvertently switched during manual entry into the COD system. Corrective Standard: The Withdrawal Date must be verified as the actual Last Date of Engagement (LDE), while the Date of Determination must remain the Banner-stamped withdrawal date. Develop and Implement Data Verification Processes: To prevent recurrence, the following "intrusive checks and balances" system has been implemented: Multi-Tier R2T4 Review (Financial Aid) - A four-point verification process is now mandatory for all Pro-rata calculations: a. Preparation: Financial Aid Specialist calculates the return based on Banner data. b. Validation: Financial Aid Coordinator validates the LDE and DOD against the academic record. c. Confirmation: Financial Aid Manager reviews and confirms previous calculations based on LDE and Banner data. d. Final Oversight: The Director of Financial Aid performs the final verification check before and after the data is committed to the Common Origination and Disbursement (COD) system. e. Standardization: All calculations must include employee initials and date within the Pro-rata Calculation Form, based on the 4-point verification process above, to ensure internal record reconciliation. Person(s) Responsible: Christine Genenbacher-Leinbach, Director of Financial Aid Brittany McKeown, Head of Enrollment, Registrar, Financial Aid Services Timing for Implementation: Currently implemented, as well as a retroactive check of prior R2T4 submissions, starting September 1, 2025. New verification tiers are active as of the current term to ensure immediate compliance without further incidents.
FAC accepted this audit on December 13, 2024 — management decision was due June 13, 2025.
The examination disclosed 6 students, out of 25 student files who had an enrollment status change tested, in which their enrollment status was inaccurately reported. Student A – The student's last day of attendance was 9/6/23 but the effective date of withdraw was reported to NSLDS as 9/22/23. Student B - The student's last day of attendance was 3/1/24 but the effective date of withdraw was reported to NSLDS as 4/8/24. Student C – The student's last day of attendance was 4/12/24 but the effective date of withdraw was reported to NSLDS as 5/15/24. Student D – The student's last day of attendance was 10/16/23 but the effective date of withdraw was reported to NSLDS as 12/15/23. Student E – The student's graduation date according to the institution was 5/16/24 but the effective date of graduation was reported to NSLDS as 5/9/24. Student F – The certification date for the status update was on 9/20/24, 196 days after the student’s effective date of withdraw.
Show full finding ▾Hide full finding ▴The examination disclosed 6 students, out of 25 student files who had an enrollment status change tested, in which their enrollment status was inaccurately reported. Student A – The student's last day of attendance was 9/6/23 but the effective date of withdraw was reported to NSLDS as 9/22/23. Student B - The student's last day of attendance was 3/1/24 but the effective date of withdraw was reported to NSLDS as 4/8/24. Student C – The student's last day of attendance was 4/12/24 but the effective date of withdraw was reported to NSLDS as 5/15/24. Student D – The student's last day of attendance was 10/16/23 but the effective date of withdraw was reported to NSLDS as 12/15/23. Student E – The student's graduation date according to the institution was 5/16/24 but the effective date of graduation was reported to NSLDS as 5/9/24. Student F – The certification date for the status update was on 9/20/24, 196 days after the student’s effective date of withdraw.
Corrective Action Plan for CmTent Year Findings To address findings of incorrect reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS), this corrective action plan outlines specific actions for data accuracy and compliance. Identify and Analyze Errors: A review of reporting errors has identified several cases that require attention. In one case, a student's data incorrectly pulled a 5/9/2024 date despite a correct graduation record in Banner; this was corrected in the Clearinghouse on 10/21/2024. Another report, dated 5/24/2024, showed a 3/1 /2024 effective date, yet the student was not on subsequent reports due to non-enrollment. This effective date was updated to 3/8/2024 in the Clearinghouse on 10/21/2024 to reflect the last day of the 1st 8-week term. A further error occurred on 9/22/23, marking a student's status as WW in Banner, though verification required an effective date change to 9/6/2023; this correction was made manually on 10/31/2024 in the Clearinghouse. Additionally, some students reported as withdrawn 0N A/WI) after mid-term need adjustment to WW/WB based on the Last Date of Attendance (LDA) provided by instructors. In one case, a student's status changed from WA on 10/30/23 to WB on 11/15/23 and back to WA on 11/15/23 to align with LDA post-mid-tenn. To note, corrections made directly in Clearinghouse could take several months to update in NSLDS. The primary issue identified is reporting based on the status date instead of LDA. To address this, all PRORATA calculations will be reviewed and updated as needed. Develop and Implement Data Verification Processes: To improve reporting accuracy, the Registrar's Office will implement a structured data verification process. This process will include regular checks on enrollment status changes, graduation dates, and NSLDS-required fields, with monthly data reviews to identify and correct discrepancies before submission. Each check will include data validation, internal record reconciliation, and a standardized checklist. A tracking system will be used to log issues, corrections, and verification status, providing a clear record of any adjustments made. Monthly meetings will be held to review verification results and address outstanding issues, while quarterly reports will be submitted to leadership to smnmarize trends, outcomes, and corrective actions taken. Implementation will begin by November 1, 2024, with monthly verification checks following. This approach aims to create a documented and reliable process to ensure data accuracy, reduce error rates, and maintain accountabilities for all corrections. Person(s) Responsible: Dean of Business Services and Institutional Effectiveness; Head of Enrollment, Registrar, and Financial Aid Services, Director of Financial Aid, Director of Fiscal Services Timing for Implementation: In progress to comply without any further incidents of non-compliance.
FAC accepted this audit on December 15, 2022 — management decision was due June 15, 2023.
See Schedule of Findings and Questioned Costs
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