EIN: 430908094
UEI: GBSKB4SK68L6
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 20, 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 20, 2026 (29 days from today).
What is a management decision? →During our review of grant disbursements, the College was unable to provide formal documentation to demonstrate that a suspension and debarment check was completed for all disbursements selected for testing. Context: For all (two) of the transactions selected for testing, the College was unable to provide documentation to support the date suspension and debarment checks were verified. Questioned costs: None Cause: The absence of formal documentation suggests that either the check was not performed or was performed but not properly documented Effect: Failure to document suspension and debarment checks could result in noncompliance with federal regulations and institutional policy, increasing the risk of disallowed costs and potential reputational or financial consequences. Repeat finding: No Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. View of responsible official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Award Period: July 1, 2024, to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Per 2 CFR 200.213, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Verification must be performed through SAM.gov, a written certification, or inclusion of the appropriate clause in the agreement. Condition: During our review of grant disbursements, the College was unable to provide formal documentation to demonstrate that a suspension and debarment check was completed for all disbursements selected for testing. Context: For all (two) of the transactions selected for testing, the College was unable to provide documentation to support the date suspension and debarment checks were verified. Questioned costs: None Cause: The absence of formal documentation suggests that either the check was not performed or was performed but not properly documented Effect: Failure to document suspension and debarment checks could result in noncompliance with federal regulations and institutional policy, increasing the risk of disallowed costs and potential reputational or financial consequences. Repeat finding: No Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. View of responsible official: There is no disagreement with the audit finding.
Coronavirus State & Local Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College verified the status of all vendors utilized in federal grant disbursements during the year ended June 30, 2025. A spreadsheet was maintained during that year which documented this. Since June 30, 2025, a procedure has been added to retain copies of the sam.gov verifications for additional documentation. Name(s) of the contact person(s) responsible for corrective action: Susan Spencer, Vice President for Finance Planned completion date for corrective action plan: Completed March 2026 If the United States Department of Treasury has questions regarding this plan, please call Susan Spencer at 660-263-4100, ext. 11274.
FAC accepted this audit on January 16, 2025 — management decision was due July 16, 2025.
During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement. Repeat finding: Yes; prior year finding number was 2023-002. Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Show full finding ▾Hide full finding ▴2024 – 001: Return of Title IV Funds Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement. Repeat finding: Yes; prior year finding number was 2023-002. Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024-001: Return of Federal Funds Context: During our testing of 40 student’s R2T4 calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Cause: The college has not implemented precise controls to ensure timely return of funds related to withdrawals. View of the responsible official: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required – usually within 1-5 days from the date it is discovered. This finding of a “late return” is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college’s attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Registrar, Deans, and Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.
2023-002
During inquiries with management, the College identified four students that they were unable to validate their high school transcripts. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. Questioned costs: $19,435 Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435. Repeat finding: No Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulation, 34 CFR 668.16(f), states the College is required to develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs. Condition: During inquiries with management, the College identified four students that they were unable to validate their high school transcripts. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. Questioned costs: $19,435 Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Effect: The College disbursed funds to four ineligible students, resulting in questioned costs of $19,435. Repeat finding: No Recommendation: We recommend the College review their internal control procedures to ensure that students are eligible prior to funds being disbursed. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024-002: Eligibility Cause: During our testing, we identified that the College’s internal control policies were not effectively designed to ensure funds are disbursed to eligible students. Context: During inquiries with management, the College identified four students that were awarded and disbursed Pell, SEOG, and Direct Loans, who were subsequently determined to be ineligible for the programs. View of the responsible official: MACC does not agree with this finding. MACC has many measures in place to ensure funds are disbursed to eligible students, including verifying identity when enrolling degree seeking students in classes each semester and reviewing high school completion status with a high school transcript, as well as reviewing ISIRs, and other documentation to determine eligibility for federal student aid. While preparing disbursements for fall 2024, the Financial Aid Office identified some odd entries on some ISIRs, which prompted us to review various patterns in admissions documents. MACC believes the students in question may be cases of stolen identities. However, this is only suspicion at this time because when the students in question enrolled in the summer 2024 semester they provided identification, submitted high school transcripts from valid high schools, completed FAFSAs which resulted with valid ISIRs (in one case the student submitted Verification (V4) documentation), submitted loan data sheets and completed entrance counseling via Zoom. The students in question were referred to the Office of Inspector General at the U. S. Department of Education on 10/15/2024; no follow-up has been received from OIG as of 01/15/2025. MACC has also discussed this case with Kathy Feith, Region 7 Branch Chief, of the U. S. Department of Education, Federal Student Aid. During an interview with an auditor from CLA, MACC disclosed the situation described above to the auditor when questioned about any potential fraud cases. MACC firmly believes all internal control policies were followed to ensure funds were disbursed to eligible students. At the time of disbursement, there was no indication these students were not eligible. As noted above, the OIG has not determined that these are in fact ineligible students; therefore, MACC does not believe it should return funds based on suspicion of ineligibility. As a result of these findings, MACC has added new steps to provide an additional layer of protection, including verifying images of state drivers licenses or other forms of identity, and development of guidelines for staff to follow if they have any suspicion of fraud. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Show full finding ▾Hide full finding ▴Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024-003: National Student Loan Data System Condition: The college did not properly report student enrollment changes for students who received federal student aid to NSLDS. Context: During testing of 60 students, 15 students were enrollment changes submitted past 60 days, 6 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 6 had program enrollment effective dates that did not match institutional records, 4 had incorrect program enrollment statuses, and 4 had incorrect program begin dates. Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. View of responsible official: MACC believes some of the current audit finding may be attributed to the SIS system implemented in November 2022; and these finding occurred before we implemented our Corrective Action Plan, which we have faithfully followed every month. As noted below, our CAP is a process in which we review enrollment records reported to NSLDS and update, if needed. Supporting documentation and verification of the work that has been done this past year can be provided, if needed. As a result of the continued commitment to submit correct data from our system to NSLDS every month, this fall MACC paid more than $12,000 to our software vendor (Jenzabar) for enhancements needed to collect, retain and report enrollment data. • Jenzabar created and installed a custom process to update the NSC status start date and NSC program status start date to the Last Date of Attendance. We began running this custom process with the November 2024 NSC enrollment file. • Jenzabar created and installed a custom process to update program begin dates for students returning to the same program to the original program begin date. We have implemented this as a scheduled process beginning December 2024. We are confident future reviews of our NSLDS enrollment reporting records will reflect greater accuracy. MACC would like to note, although the auditors are noting several students with effective date issues and failure to report students timely, we have evidence of student records being exported from our system every month and recorded in the Program Certification Details within NSLDS, but the data is not found in the Program Enrollment Effective Date area of NSLDS. We acknowledge the data must be in both areas of NSLDS, but we believe there is evidence that we submitted our records as required. We are hopeful the new enhancements will correct this issue. As disclosed in our audit response for 2022-2023, the corrective action plan has been slightly altered, but continues: • The Registrar will review data in J1 and submit enrollment records to NSC each month. • The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. • After the enrollment file is accepted by NSC, MACC will review correct enrollment information in NSLDS for all students who have withdrawn from all classes and/or have had an R2T4 calculation, for accuracy. o The Registrar, or designee, will review the data in NSC. o The Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
2023-003
FAC accepted this audit on February 14, 2024 — management decision was due August 14, 2024.
CLA noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Questioned costs: None Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: CLA recommends that the student financial aid department review and revise processes and controls related to disbursements are reported to COD within 15 days of the disbursement date. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Show full finding ▾Hide full finding ▴2023 – 001: Common Origination and Disbursement Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: CLA noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Questioned costs: None Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: CLA recommends that the student financial aid department review and revise processes and controls related to disbursements are reported to COD within 15 days of the disbursement date. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: As a standard, regular practice, communicates disbursement information for Federal Pell and Federal loans to COD no less than once per week; therefore, we believe we have an adequate way to report disbursements to COD within 15 days of the disbursement date. MACC transitioned to new financial aid processing software (Jenzabar Financial Aid - JFA) in summer 2022 while other areas of the college were still using the "old" system (Jenzabar CX). We experienced a glitch during the transition in which the files did not update as expected, we worked with our software vendor to correct the issue. Below is the timeline of action taken:This finding pertains to one student with Sub and Unsub Loans. We posted aid and sent the original batch on Friday, 07/15/2022; we discovered the issue on Wednesday, 07/20/2022, and reached out to Jenzabar immediately; we followed up with Jenzabar on Thursday, 07/28/2022 because the records were not updated; the records were updated on Monday, August 1. Action taken in response to finding: MACC continues to submit disbursement information at least once per week and review student details for posting accuracy. We took the necessary steps to fix the issue. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We believe this finding was an anomaly due to the system conversion. We have no evidence of this happening since.
During testing of Return of Title IV funds, the College did not return Title IV funds within 45-days of the College's determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45-day requirement. Repeat finding: No Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Show full finding ▾Hide full finding ▴2023 – 002: Return of Title IV funds Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45-days of the College's determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45-day requirement. Repeat finding: No Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required - usually within 1-5 days from the date it is discovered. This finding of a "late return" is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college's attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.
The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted student enrollment status changes were not properly reported or updated during the Spring 2023 term. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Show full finding ▾Hide full finding ▴2023 – 003: National Student Loan Data System Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Material Noncompliance (Modified Opinion) • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted student enrollment status changes were not properly reported or updated during the Spring 2023 term. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding, but we offer the following explanation: Identification of Errors and Corrections to New SIS: • Conversion to a new SIS (Jenzabar - Jl) was effective November 2022, and forced subsequent Fall 2022 NSC Enrollment Transmittal Files to be created in the new system mid-term. The concern of enrollment report timing was brought to the vendor multiple times before the transition. However, due to scheduling limitations on the vendor's end, the transition to the new system had to be completed mid-term. • In late May/early June we began end of term processing and reconciliations, and we identified that student status changes were not properly pulling the correct enrollment status information through the vendor's enrollment report creation process. • Support tickets were sent to the vendor immediately to address the problems with the system process that creates NSC Transmittal Files. • System configuration changes were made as recommended by the vendor to properly update enrollment status changes. • Through the investigation of these configuration changes, additional system errors were identified that were not allowing some enrolled students to be properly pulled to the enrollment files. • Support engagements continued with the vendor throughout July and August to identify and correct the system configuration to correctly pull enrolled students into the NSC Transmittal File. This was completed by the end of summer term, and the final summer enrollment file contained the correct number of students enrolled with the correct final enrollment status. • Internal validation reports were created and executed to ensure that correct student data was transmitted on the Fall first of Term reports. We believe this transmission contained the correct number of students and the correct status. These internal validation reports will be conducted prior to all NSC submissions. Creation of new/additional reports will be conducted as necessary. • We have been able to verify that the Fall 2023 subsequent term enrollment file did contain accurate status change information, and this issue is now resolved. • By correcting status change configurations, we have also identified that program begin dates converted from the old SIS to the new SIS were incorrectly mapped. • We are currently in the process of identifying the ID#s with incorrect program begin dates and making manual updates to the students' record in the new SIS environment. The vendor has not provided a clear path to programmatically correct this in bulk, so this record validation is being completed one-by-one manually. We project to have this completed for currently enrolled students by the final fall 2023 enrollment submission. Correcting previously submitted data: • We reached out to our Data Analyst, Elizabeth Fennessy, with the National Student Clearinghouse, to begin working on a corrective action for the missing status change data. • Elizabeth consulted with the NSC Audit Resource Team, and the following plan was recommended to MACC: • For students Less Than Half Time Spring 2023 or Withdrawn Spring 2023 that re-enrolled Summer 2023, these would be a manual update in NSLDS for Title IV students in these scenarios using NSLDS site 'Enrollment History Update.' • Later in Clearinghouse, the same update can be reflected using Clearinghouse site 'Student Look-Up' to bring the record current with updated enrollment reflected Spring 2023. By updating NSLDS first, that will avoid an NSLDS error "certification date out of sync" (error code 32). • MACC prepared reports to retrieve students meeting the criteria identified above. • These students' enrollment statuses for Spring 2023 and Summer 2023 have been manually updated in NSLDS Enrollment History Update and in NSC Student Look-up to bring these enrollment statuses up to date; this has been a long and time-consuming process. • We are also currently working on reports to identify students that were enrolled in spring 2023 but missed when the NSC Enrollment Transmittal File was created. We believe that students missed in Summer 2023 have been brought up to date through the submission of the corrected final Summer 2023 Enrollment File (to include students that were also enrolled in Spring 2023). Any student that was inadvertently excluded from the Spring 2023 and has not been brought up to date through subsequent corrected submissions, will be manually corrected through NSC Student Look-Up, and NSLDS Enrollment History Update if necessary. • We also reached out to l<athy Feith, Branch Chief, l<C School Participation Division, Federal Student Aid, U.S. Department of Education; she is aware of our issues. She recommended making enrollment changes directly in NSLDS for students who withdrew. Action taken in response to finding: The following is our Corrective Action Plan. • The Registrar will review data in J1 and submit enrollment records to NSC each month. o The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. o MACC will continue to work with Jenzabar for a solution for reporting last dates of attendance for students who are withdrawn from all classes. • After the enrollment file is accepted by NSC, 20 randomly selected students will be verified for accuracy. • The selection will be made by the Director of FA and/or Registrar. • The selection will include students who have withdrawn from all classes and had an R2T4 calculation performed. • The Registrar, or designee, will review the data in NSC. • The Associate Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
FAC accepted this audit on December 9, 2021 — management decision was due June 9, 2022.
During our testing, we noted that 17 out of 40 students tested where the student was not reported in a timely manner. Questioned costs: None Context: In connection to prior year audit finding (2020-003), the College implemented their corrective action plan to correct the effective date of enrollment status changes related to withdrawals on January 15, 2021. Due to the corrective action implemented, the corrected change in enrollment status dates were not received within the required timeframe for Fall R2T4s. The auditors noted that corrective action was properly implemented to correct the deficiency moving forward. Cause: The College implemented their corrective action plan related to the prior year audit finding (2020 003). The planned completion date of the corrective action plan related to prior year audit finding (2020-003) was January 15, 2021. Due to the timing of the corrective action taken, the corrected students from the fall semester were not reported within the 60-day required timeframe. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes; 2020-003 Recommendation: Corrective action was taken during fiscal year 2021. No further recommendation is needed. Views of responsible officials: MACC continues to follow the action plan presented as a result of this finding the 2020 audit, with the following update: our data extract from Jenzabar CX can now pull Last Date of Attendance for students who have withdrawn from all courses. We are still manually updating the LDA for R2T4 students that completed a module or completed the term with an unearned F
Show full finding ▾Hide full finding ▴2021? 001 NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Assistance Listing Number: Student Financial Assistance Cluster Award Period: July 1, 2020 to June 30, 2021 Type of Finding: ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted that 17 out of 40 students tested where the student was not reported in a timely manner. Questioned costs: None Context: In connection to prior year audit finding (2020-003), the College implemented their corrective action plan to correct the effective date of enrollment status changes related to withdrawals on January 15, 2021. Due to the corrective action implemented, the corrected change in enrollment status dates were not received within the required timeframe for Fall R2T4s. The auditors noted that corrective action was properly implemented to correct the deficiency moving forward. Cause: The College implemented their corrective action plan related to the prior year audit finding (2020 003). The planned completion date of the corrective action plan related to prior year audit finding (2020-003) was January 15, 2021. Due to the timing of the corrective action taken, the corrected students from the fall semester were not reported within the 60-day required timeframe. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes; 2020-003 Recommendation: Corrective action was taken during fiscal year 2021. No further recommendation is needed. Views of responsible officials: MACC continues to follow the action plan presented as a result of this finding the 2020 audit, with the following update: our data extract from Jenzabar CX can now pull Last Date of Attendance for students who have withdrawn from all courses. We are still manually updating the LDA for R2T4 students that completed a module or completed the term with an unearned F
2021-001 NSLDS Enrollment Reporting ? Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: Corrective action was taken in fiscal year 2021. No further recommendation is needed. . Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: None. Corrective action in response to audit finding 2020-003 was completed on January 15, 2021. MACC continues to follow the action plan presented as a result of this finding the 2020 audit, with the following update: our data extract from Jenzabar CX can now pull Last Date of Attendance for students who have withdrawn from all courses. We are still manually updating the LDA for R2T4 students that completed a module or completed the term with an unearned F. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: January 15, 2021
2020-003
FAC accepted this audit on April 26, 2021 — management decision was due October 26, 2021.
During our testing, we noted that the rosters returned for the College yielded error reports that were not corrected and resubmitted within the required 10 days throughout the year. Questioned Costs: None Context: During our review of the SCHER1 reports, we noted error records were not being corrected and resubmitted within the required 10 days. Cause: The College did not have processes and controls in place to ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend that the Business Office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the ten-day timeframe required. Views of responsible officials: MACC has implemented a new procedure in which monthly reviews will be conducted by the financial aid director to verify compliance has been satisfied. This review will be conducted by reviewing SCHER1 reports and correspondence submitted to NSC/NSLDS.
Show full finding ▾Hide full finding ▴2020 ? 002 National Student Loan Data System (NSLDS) Error Correcting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted that the rosters returned for the College yielded error reports that were not corrected and resubmitted within the required 10 days throughout the year. Questioned Costs: None Context: During our review of the SCHER1 reports, we noted error records were not being corrected and resubmitted within the required 10 days. Cause: The College did not have processes and controls in place to ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend that the Business Office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the ten-day timeframe required. Views of responsible officials: MACC has implemented a new procedure in which monthly reviews will be conducted by the financial aid director to verify compliance has been satisfied. This review will be conducted by reviewing SCHER1 reports and correspondence submitted to NSC/NSLDS.
2020-002 National Student Loan Data System (NSLDS) Error Correcting Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the Business Office and the Financial Aid office work with NCS to ensure that error record corrections are properly reported to NSLDS within the 10 day timeframe required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MACC works diligently to ensure enrollment records are submitted properly and timely to NSLDS each month. This audit has brought to light some deficiencies in our process, however. A collaboration of MACC staff (financial aid, computer services, and Registrar) will review the SCHER1 each month and will investigate errors and make necessary updates. If/when an error is unable to be corrected with NCS, MACC staff will persist in their investigation to correct the errors and ultimate reporting to NSLDS. Necessary updates will be made within 5 days in order to allow NCS time to submit corrections to NSLDS within the 10 day time limit. Additionally, MACC has implemented a new procedure in which monthly reviews will be conducted by the financial aid director to verify compliance has been satisfied. This review will be conducted by reviewing SCHER1 reports and correspondence submitted to NSC/NSLDS. . Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: January 15, 2021
During our testing, we noted that 11 out of 40 students tested where the student was not reported in a timely manner. We also noted that 32 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date in the College?s records. We also noted that 11 out of the 40 students tested, the enrollment status reported to NSLDS did not match the College?s records. Lastly, we noted that one out of the 40 students tested, the program begin date reported to NSLDS did not match the College?s Records for first date of attendance in the corresponding reported program. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The College did not timely or accurately report student enrollment information to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: MACC has an established monthly reporting schedule with NSC, and staff from the financial aid office and computer services department work diligently to ensure enrollment records are submitted properly and timely to NSLDS each month. Additionally, MACC has implemented a new procedure in which monthly reviews will be conducted by the financial aid director to verify compliance has been satisfied. This review will include random selection of student records, verifying NSLDS data submission matches college records.
Show full finding ▾Hide full finding ▴2020 ? 003 NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted that 11 out of 40 students tested where the student was not reported in a timely manner. We also noted that 32 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date in the College?s records. We also noted that 11 out of the 40 students tested, the enrollment status reported to NSLDS did not match the College?s records. Lastly, we noted that one out of the 40 students tested, the program begin date reported to NSLDS did not match the College?s Records for first date of attendance in the corresponding reported program. Questioned Costs: None Context: During our testing, it was noted the College does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The College did not timely or accurately report student enrollment information to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: MACC has an established monthly reporting schedule with NSC, and staff from the financial aid office and computer services department work diligently to ensure enrollment records are submitted properly and timely to NSLDS each month. Additionally, MACC has implemented a new procedure in which monthly reviews will be conducted by the financial aid director to verify compliance has been satisfied. This review will include random selection of student records, verifying NSLDS data submission matches college records.
2020-003 NSLDS Enrollment Reporting Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: MACC has an established monthly reporting schedule with NSC, and staff from the financial aid office and computer services department work diligently to ensure enrollment records are submitted properly and timely to NSLDS each month. Our process has been to extract records from Jenzabar CX, send to NSC, and NSC transmits the data to NSLDS. This audit has brought to light some deficiencies in our process, however. Through continued collaborative efforts between the Computer Services, Financial Aid, and Registrar?s Offices, the process is currently under review to identify weaknesses and compliance issues. Action taken in response to finding: We are working with our software vendor to include the last date of attendance for each student who is being reported as a total withdrawal from the semester (previously our system extracted the date the last drop was entered into the system). Until Jenzabar CX is able to extract the LDA for each student, MACC staff will manually update the LDA?s directly with NSC and NSLDS to ensure timely and accurate data is reported. Additionally, the audit also helped us discover that our software system was incorrectly updating student enrollment status to Less-Than-Half-Time, rather than the correct Withdrawn status. This was due to a system reporting component (leave record) that was not fully understood by MACC staff. We have learned that records submitted for students with a Withdrawn status, past the semester end date, must have a leave record with a date past the last day of the term. To correct this problem, and to ensure accurate status records are submitted, the end date in the leave record will be 3 weeks past the last day of the semester. Additionally, MACC has implemented a new procedure in which monthly reviews will be conducted by the financial aid director to verify compliance has been satisfied. This review will include random selection of student records, verifying NSLDS data submission matches college records. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: January 15, 2021
Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Context: During our audit procedures, it was noted that the College did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: College management was unaware of requirement. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 004 Gramm-Leach-Bliley Act ? Student Information Security Federal agency: U.S. Department of Education Federal program title: Student Financial Aid CFDA Numbers: 84.007, 84.033, 84.063, 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Context: During our audit procedures, it was noted that the College did not designate an individual to coordinate the information security program; perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: College management was unaware of requirement. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2020-004 Gramm-Leach-Bliley Act ? Student Information Security Student Financial Aid Cluster ? CFDA No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the College designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has an active cybersecurity committee that has been developing policies and procedures over the last year. An external risk assessment was performed in FY1920, and a number of measures have been taken in response to this. The committee is currently performing their own college wide cybersecurity risk assessment. Subsequent to the audit, a GLBA Policy has been drafted, a security officer has been named, and a GLBA specific risk assessment has been performed, which addresses the required standards. All policies will be reviewed annually and any changes, as well as annual assessment results, will be presented to the board for approval. Name(s) of the contact person(s) responsible for corrective action: Susan Spencer, VP for Finance Planned completion date for corrective action plan: June 30, 2021
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