EIN: 440545271
UEI: J4C4KJBAAM33
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 18, 2025. 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 June 18, 2026 (68 days ago).
What is a management decision? →During our testing of thirty-seven student files, we noted two individuals (5.4%) that were not properly awarded Direct Loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-003. Statistical sampling was not used in making sample selections. Questioned Costs: $1,000 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.” Condition: During our testing of thirty-seven student files, we noted two individuals (5.4%) that were not properly awarded Direct Loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-003. Statistical sampling was not used in making sample selections. Questioned Costs: $1,000 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: During our testing of thirty-seven student files, we noted two individuals (5.4%) that were not properly awarded Direct Loans. Corrective Action Plan: Twice each Fall and Spring semester, Hannah Masters will request an updated report of enrolled student year status from the Registrar, Chayna Penney. She will compare these statuses to the year-in-school information reported by students on their FAFSA, which is housed in the PowerFAIDS software. If any discrepancies are identified, Hannah will submit a FAFSA correction on behalf of the student, import the correction into PowerFAIDS, and review and recalculate the student’s financial aid. The student will then be repackaged appropriately, and an updated aid offer will be generated. Finally, Hannah will notify the student by email regarding the changes made to their account and will connect them with the Business Office and Registrar’s Office for any additional follow-up. This process was completed on October 1, 2025, for the Fall 2025 term, and a second review for Fall 2025 is scheduled for December 1, 2025. Responsible Person for Correction Action Plan: Hannah Masters, Executive Director of Financial Aid Chayna Penney, Registrar Implementation Date for Corrective Action Plan: October 01, 2025
2024-003
The College did not accurately timely and accurately complete refund calculations for 1 out of 4 students (25%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-005. Questioned Costs: $6,355 Effect: Miscalculation of the percentage of days attended in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2025-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22). Condition: The College did not accurately timely and accurately complete refund calculations for 1 out of 4 students (25%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-005. Questioned Costs: $6,355 Effect: Miscalculation of the percentage of days attended in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: The College did not accurately timely and accurately complete refund calculations for 1 out of 4 students (25%) tested. We consider this finding to be a significant deficiency in relation to the Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2024-005. Corrective Action Plan: Cynthia Lawrence in the Business Office will conduct a secondary full review of each R2T4 form completed by Hannah Masters, the student’s account statement and balance in Jenzabar, the withdrawal form supplied by the Registrar, the withdrawal date reported in Jenzabar by the Registrar, and any last date of attendance documentation provided by faculty or the Registrar. If any discrepancies are identified, Cynthia will notify both Hannah Masters and the Registrar’s team by email, outlining the issue. Once corrections are submitted, Cynthia will review the updated materials to ensure accuracy and compliance. Responsible Person for Correction Action Plan: Hannah Masters, Executive Director of Financial Aid and Student Accounts Cynthia Lawrence, Accounts Receivable / Staff Accountant Implementation Date for Corrective Action Plan: October 15, 2025
2024-005
FAC accepted this audit on March 5, 2025 — management decision was due September 5, 2025.
During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $143 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-002 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024 Criteria: 34 CFR 690.62 states, “The amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $143 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Students should receive the proper amount of aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) was not properly awarded Pell grants Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and reviewing federal awards. Throughout the 2024-25 school year, we have implemented quarterly internal audits where students are randomly selected and processed through an internal review of their federal awards. Through this new process, we are reviewing Federal Pell, FSEOG and Federal Work Study eligibility, disbursement dates, and documentation for each student. By completing this process quarterly, we will be able to do an additional review of each student in detail while the school year is still in session and corrections can be made. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) Implementation Date for Corrective Action Plan: 01/30/2025
During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year findings 2023-003 and 2023-006. Statistical sampling was not used in making sample selections. Questioned Costs: $3,199 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-003 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024 Criteria: 34 CFR 682.201 (a) (1-2) notes, “(1) To obtain a Direct Subsidized Loan or a Direct Unsubsidized Loan, a student must complete a Free application for Federal Student Aid and submit it in accordance with instructions in the application. (2) If the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: (i) create a loan origination record and transmit the record to the Secretary. (ii) Ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary. (iii) In accordance with 34 CFR 668.162, draw down funds or receive funds from the Secretary, and disburse the funds to the student.” Condition: During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans. We consider this condition to be a significant deficiency relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year findings 2023-003 and 2023-006. Statistical sampling was not used in making sample selections. Questioned Costs: $3,199 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend the College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: During our testing of thirty-seven student files, we noted ten individuals (27%) that were not properly awarded Direct Loans. Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and reviewing Federal Loans. Throughout the 2024-25 school year, we have implemented quarterly internal audits where students are randomly selected and processed through an internal review of their federal awards. Through this new process, we are reviewing loan eligibility, disbursement dates, and documentation for each student. By completing this process quarterly, we will be able to do an additional review of each student in detail while the school year is still in session and corrections can be made. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) Implementation Date for Corrective Action Plan: 01/30/2025
2023-003, 2023-006
Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College had made corrections to individuals’ accounts that were not reported and reflected in COD. Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-004 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024 Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections. Questioned Costs: N/A Cause and Effect: The College had made corrections to individuals’ accounts that were not reported and reflected in COD. Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: Cottey College did not report the correct loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 37 students in the sample (5.4%). We consider this condition to be an instance of noncompliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-004. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the month of October 2024, a financial aid consultant met with Cottey staff to discuss and plan better procedures related to awarding and reviewing Federal Loans. Throughout the 2024-25 school year, we have implemented quarterly internal audits where students are randomly selected and processed through an internal review of their federal awards. Through this new process, we are reviewing loan eligibility, disbursement dates, and documentation for each student. By completing this process quarterly, we will be able to do an additional review of each student in detail while the school year is still in session and corrections can be made. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) Implementation Date for Corrective Action Plan: 01/30/2025
2023-004
The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections. Questioned Costs: $350 Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2024-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22). Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections. Questioned Costs: $350 Effect: Miscalculation of the days in addition to incorrect inputs for awards that were disbursed and not disbursed in the Return of Title IV funds calculations results in incorrect amounts returned by the College. Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections. Corrective Action Plan: This repeated finding was due to our previously delayed audits. We implemented the plan below on 09/10/2024 after the 2023-05 finding, however, the 2023-24 school year had already completed. This meant we were unable to make changes in the year as it had already concluded, and we implemented the corrective action plan for the 2024-25 school year. 2023-005 Corrective Action Plan: Corrective Action Plan: The Registrar’s Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4’s for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: 01/30/2025
2023-005
FAC accepted this audit on October 29, 2024 — management decision was due April 29, 2025.
During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,002 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend Cottey College reclassify $5,002 from subsidized to unsubsidized. 2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student's estimated cost of attendance for the period of enrollment less the borrower's expected family contribution and estimated financial assistance for that period (34 CFR 685.203). Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,002 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. Recommendation: We recommend Cottey College reclassify $5,002 from subsidized to unsubsidized. 2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Upon census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023
Cottey College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Questioned Costs: $16,444 Cause and Effect: Cottey College noted this was an error that occurred but did not occur with the entire batches. Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.164 (a)(1) states "Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student's ledger account or pays the student or parent directly with - (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds; Condition: Cottey College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Questioned Costs: $16,444 Cause and Effect: Cottey College noted this was an error that occurred but did not occur with the entire batches. Recommendation: We recommend Cottey College implement procedures in order to report accurate disbursements dates for Direct Loans to COD. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 worked in the financial aid office. After retiring, a new position was created that is split between the Business Office and Financial Aid and Student Accounts office. This position now reviews student accounts weekly, and during that review they compare the date of disbursement to the student account and the date of disbursement in COD. Through this process, any mismatched dates are corrected and updated to COD. Due to the audit completion delay, our action plan for the previous audit could not be put into place before the year had already been completed. Below is the previous audit plan to show that it was implemented, however, timing meant implementation happened after the 2022-23 year had ended. The financial aid office is currently hiring for a new position that will oversee student accounts. Once this position is filled, we will implement our updated policy and procedure that requires review and collaboration to monitor COD disbursement date, financial aid software disbursement date and student billing statement disbursement date. This will ensure both financial aid staff and student accounts staff will confirm each date in all areas. Planned completion date for corrective action plan: 06/30/2023 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023
2022-003
Cottey College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $32 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by Cottey College. Recommendation: We recommend Cottey College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: 34 CFR 668.22 (a)(1) states "When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section." 34 CFR 668.22 (e)(2) states, "The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or..." 34 CFR 668.22(j) notes, "(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b)." An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student's account for outstanding charges (34 CFR 668.22). Condition: Cottey College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $32 Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by Cottey College. Recommendation: We recommend Cottey College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: The Registrar's Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4's for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024
During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,436 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is students received unsubsidized loans prior to receiving full subsidized loans. Recommendation: We recommend Cottey College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: In the case of an undergraduate student who has successfully completed the first and second years of a program of study of undergraduate education but has not successfully completed the remainder of the program, the total amount the student may borrow for any academic year of study under the Direct Subsidized Loan Program may not exceed the following: $5,500 for a program of study of at least an academic year in length (34 CFR 685.203). Condition: During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $5,436 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is students received unsubsidized loans prior to receiving full subsidized loans. Recommendation: We recommend Cottey College evaluate policies and procedures to ensure students receive the proper amount of Title IV aid. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Upon her retirement, Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Then on census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023
Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution received those funds from the Secretary or deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. An institution may maintain for up to seven days an amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The institution must return immediately to the Secretary any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the seven-day tolerance period. (34 CFR 668.163, 668.166). Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Questioned Costs: $25,644. Effect: As a result, the Institution is retaining federal monies longer than allowed. Recommendation: We recommend Cottey College implement procedures and cash controls to avoid having excess cash. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-007 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: Throughout the year cash on hand exceeded the immediate disbursement needs for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency in internal control over compliance relating to the Cash Management compliance requirement and is not a repeat finding. Corrective Action Plan: During the 2022-23 fiscal year, SEOG and Federal Work Study funds were drawn when funds were authorized, not when funds were expended. The mistake was realized in the Federal Work Study draw and the funds were returned, but the SEOG draw was not refunded. The funds were subsequently awarded. Going forward all Federal Funds will be drawn after they are awarded. Responsible Person for Correction Action Plan: Kevin Smithberger Implementation Date for Corrective Action Plan: August 2024
During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $1,969 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is a student received ineligible loan proceeds. Recommendation: We recommend Cottey College reclassify $1,969 from subsidized to unsubsidized. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Criteria: A student who has not successfully completed a program of study at the undergraduate level may not receive Federal Direct Subsidized Loans in excess of $23,000 (34 CFR 682.204). Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Questioned Costs: $1,969 Cause and Effect: Without proper review of eligibility of financial aid, students may receive an incorrect amount of Title IV aid. The result is a student received ineligible loan proceeds. Recommendation: We recommend Cottey College reclassify $1,969 from subsidized to unsubsidized. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Upon her retirement, Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Then on census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023
FAC accepted this audit on May 7, 2023 — management decision was due November 7, 2023.
During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 2 of the 8 individuals tested had used an incorrect withdrawal date. The students withdrew in between semesters therefore they should have had a withdrawal date from the previous semester; however, College reported a different date. Questioned Costs: None Context: During our testing, we noted the College had used the incorrect withdrawal date based on the student's reported date as the student withdrew in between semesters. Cause: The College used the incorrect withdrawal date thus students were incorrectly reported. Effect: The College is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. View of Responsible Official: There is no disagreement with the audit finding.
Return of Title IV Aid CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379 Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal date and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is currently hiring for a new position that will oversee student accounts. Once this position is filled, we will implement our updated policy and procedure that requires review and collaboration to monitor COD disbursement date, financial aid software disbursement date and student billing statement disbursement date. This will ensure both financial aid staff and student accounts staff will confirm each date in all areas. Name(s) of the contact person(s) responsible for corrective action: Hannah Masters Planned completion date for corrective action plan: 06/30/2023
During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College 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: During our testing, we noted 8 of the 40 disbursements were reported outside of the 15-day requirements. Furthermore, 1 of the 40 disbursement dates per COD did not align with the student account. Questioned Costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students? interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
COD Reporting CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal process has been updated to include a review of the official withdrawal date by both the Registrar and Director of Financial Aid. This will ensure that the withdrawal date reported to Jenzabar, NSLDS, R2T4 and all internal reporting is accurate. Going forward, the Director of Financial Aid will review the draft withdrawal date from the Registrar?s Office. If discrepancy or concerns are found, the Director of Financial Aid will email the Registrar, they will then work together to determine the correct date of withdrawal. Once this date is confirmed, R2T4 and NSLDS reporting will take place. Name(s) of the contact person(s) responsible for corrective action: Hannah Masters and William Stanfill Planned completion date for corrective action plan: 05/04/2023
During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 don?t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 2 of the 8 students? enrollment date per institution's record did not match the date reported to NSLDS. Questioned Costs: None Context: During our testing, we noted 2 of the 8 students enrollment date was not properly reported to NSLDS. Cause: The College processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes - 2021-003 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
NSLDS Reporting CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379 Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal process has been updated to include a review of the official withdrawal date by both the Registrar and Director of Financial Aid. This will ensure that the withdrawal date reported to Jenzabar, NSLDS, R2T4 and all internal reporting is accurate. Going forward, the Director of Financial Aid will review the draft withdrawal date from the Registrar?s Office. If discrepancy or concerns are found, the Director of Financial Aid will email the Registrar, they will then work together to determine the correct date of withdrawal. Once this date is confirmed, R2T4 and NSLDS reporting will take place. Name(s) of the contact person(s) responsible for corrective action: Hannah Masters and William Stanfill Planned completion date for corrective action plan: 05/04/2023
2021-003
During our testing, we noted: ? The December 31, 2021, and March 31, 2022, student quarterly reports did not have proper documentation of expenditure. ? The December 31, 2021, and March 31, 2022, student quarterly reports were not posted timely. ? The March 31, 2022, Institutional quarterly report was not posted timely. ? The December 31, 2021, and March 31, 2022, institutional quarterly reports were not properly reviewed prior to submission. ? The December 31, 2021, annual report was not properly reviewed prior to submission. Question Cost: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that it posted the reporting timely and accurately. Effect: The College did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Funding Assistance Numbers: 84.425E and 84.425F Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing, we noted: ? The December 31, 2021, and March 31, 2022, student quarterly reports did not have proper documentation of expenditure. ? The December 31, 2021, and March 31, 2022, student quarterly reports were not posted timely. ? The March 31, 2022, Institutional quarterly report was not posted timely. ? The December 31, 2021, and March 31, 2022, institutional quarterly reports were not properly reviewed prior to submission. ? The December 31, 2021, annual report was not properly reviewed prior to submission. Question Cost: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have someone tracking the requirements to ensure that it posted the reporting timely and accurately. Effect: The College did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Reporting CFDA No: 84.425E and 84.425F Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has already begun these changes and reports will be reviewed for accuracy and timeliness before submission to the federal agency other than the preparer. Cottey College will be compliant with federal programs? regulations and guidelines. Name(s) of the contact person(s) responsible for corrective action: Kimberly Marshall Planned completion date for corrective action plan: 06/30/2023
FAC accepted this audit on May 22, 2022 — management decision was due November 22, 2022.
During our testing of 10 students, we noted two students were reported to the National Student Loan Data System (NSLDS) with an incorrect enrollment effective date. 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 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. Also, 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. 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. Questioned Costs: None Context: During our testing, it was noted the College did not have the proper procedures in place in order to ensure the effective enrollment, programs, and status changes and dates reported to NSLDS match the College?s records and are reported timely. It was also noted that enrollment certification was not performed during the summer months. Cause: The College did not have a process in place to ensure the effective date and status reported to NSLDS matches the effective date of the student?s last date of attendance and appropriate reason for change. They also did not have a process in place to report student enrollment and program changes accurately and timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The College also did not comply with Department of Education regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: Yes Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the College?s last date of attendance. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Department of Education Federal Program: Student Financial Assistance Cluster Assistance Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing of 10 students, we noted two students were reported to the National Student Loan Data System (NSLDS) with an incorrect enrollment effective date. 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 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. Also, 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. 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. Questioned Costs: None Context: During our testing, it was noted the College did not have the proper procedures in place in order to ensure the effective enrollment, programs, and status changes and dates reported to NSLDS match the College?s records and are reported timely. It was also noted that enrollment certification was not performed during the summer months. Cause: The College did not have a process in place to ensure the effective date and status reported to NSLDS matches the effective date of the student?s last date of attendance and appropriate reason for change. They also did not have a process in place to report student enrollment and program changes accurately and timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The College also did not comply with Department of Education regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: Yes Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the College?s last date of attendance. View of Responsible Official: There is no disagreement with the audit finding.
NSLDS Reporting CFDA No: 84.007; 84.033; 84.063; 84.268; Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the College?s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will review current processes and change those processes to report in a timely and accurate fashion to ensure to be compliant with the program and federal regulations per the grant awards' specifications. Name(s) of the contact person(s) responsible for corrective action: Hannah Masters Planned completion date for corrective action plan: 8/31/2022
2020-002
The College does not have a financial policy regarding the single audit threshold and UG procurement requirements. Implementation of the procurement standards in 2 CFR sections 200.317 through 200.326 is now required for auditee fiscal years beginning on or after December 26, 2017. Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. Questioned Costs: None Context: During our testing it was noted the College does not have a financial policy regarding the single audit threshold and UG procurement requirements. Implementation of the procurement standards in 2 CFR sections 200.317 through 200.326 is now required for auditee fiscal years beginning on or after December 26, 2017. Cause: The College did not have proper procedures in place to obtain multiple quotes for federal purchases over micro-purchase thresholds. Effect: Not in compliance with Uniform Guidance regulations. Repeat Finding: No Recommendation: We recommend the College review its current procurement policy and update as needed to be in compliance with federal procurement policies. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Department of Education Higher Education Emergency Relief Funding 84.425F Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: The College does not have a financial policy regarding the single audit threshold and UG procurement requirements. Implementation of the procurement standards in 2 CFR sections 200.317 through 200.326 is now required for auditee fiscal years beginning on or after December 26, 2017. Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. Questioned Costs: None Context: During our testing it was noted the College does not have a financial policy regarding the single audit threshold and UG procurement requirements. Implementation of the procurement standards in 2 CFR sections 200.317 through 200.326 is now required for auditee fiscal years beginning on or after December 26, 2017. Cause: The College did not have proper procedures in place to obtain multiple quotes for federal purchases over micro-purchase thresholds. Effect: Not in compliance with Uniform Guidance regulations. Repeat Finding: No Recommendation: We recommend the College review its current procurement policy and update as needed to be in compliance with federal procurement policies. View of Responsible Official: There is no disagreement with the audit finding.
Procurement CFDA No: 84.425F and 84.425N Recommendation: We recommend the College review its current procurement policy and update as needed to be in compliance with federal procurement policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will establish a procurement procedural manual that will outline the federal uniform guidance requirements as it pertains to any federal grants or contracts. Name(s) of the contact person(s) responsible for corrective action: Kimberly Marshall Planned completion date for corrective action plan: 12/31/2022
During our testing, we noted: ? The annual report tested, the supporting documentation did not agree to what was included in the report. The annual report tested were not reviewed and approved prior to submission. 2 of the 2 quarterly institutional reports tested, the supporting documentation did not agree to what was included in the report. 2 of the 2 quarterly institutional reports tested were not reviewed and approved prior to posting. 3 of the 3 quarterly student reports tested were not reviewed and approved prior to posting. Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the college did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The college did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. There was also supporting documentation not retained by the colleges and universities to support the information reported at the time of the report. Effect: The college did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the college review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Department of Education Higher Education Emergency Relief Funding 84.425E and 84.425F Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted: ? The annual report tested, the supporting documentation did not agree to what was included in the report. The annual report tested were not reviewed and approved prior to submission. 2 of the 2 quarterly institutional reports tested, the supporting documentation did not agree to what was included in the report. 2 of the 2 quarterly institutional reports tested were not reviewed and approved prior to posting. 3 of the 3 quarterly student reports tested were not reviewed and approved prior to posting. Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed and the college did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The college did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. There was also supporting documentation not retained by the colleges and universities to support the information reported at the time of the report. Effect: The college did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the college review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. View of Responsible Official: There is no disagreement with the audit finding.
Reporting CFDA No: 84.425E, 84.425F and 84.425N Recommendation: We recommend the College review its reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Vice President for Finance and Administration will review all federal grant reports prior to submission to the federal agency. The College has begun the process of making corrections on the 20-21 quarterly reports as requested by the auditors. Name(s) of the contact person(s) responsible for corrective action: Kimberly Marshall Planned completion date for corrective action plan: 5/11/2022
FAC accepted this audit on April 21, 2021 — management decision was due October 21, 2021.
During our testing of 16 students, we noted five students were reported to the National Student Loan Data System (NSLDS) with an incorrect enrollment effective date, two were reported with an incorrect effective change date, two students' statuses were either incorrectly or not reported, three students' programs were either incorrectly or not reported, and two students? changes were not reported to NSLDS by the College in a timely manner. In addition, for all 12 applicable students enrolled prior to fall 2019, we noted a gap in their enrollment certification greater than 60 days during summer 2019; for one of those 12 students, a similar instance was noted for summer 2020. 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 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. Also, 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. 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. Questioned Costs: None Context: During our testing, it was noted the College did not have the proper procedures in place in order to ensure the effective enrollment, programs, and status changes and dates reported to NSLDS match the College?s records and are reported timely. It was also noted that enrollment certification was not performed during the summer months. Cause: The College did not have a process in place to ensure the effective date and status reported to NSLDS matches the effective date of the student?s last date of attendance and appropriate reason for change. They also did not have a process in place to report student enrollment and program changes accurately and timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The College also did not comply with Department of Education regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the College?s last date of attendance. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020-002: NSLDS Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing of 16 students, we noted five students were reported to the National Student Loan Data System (NSLDS) with an incorrect enrollment effective date, two were reported with an incorrect effective change date, two students' statuses were either incorrectly or not reported, three students' programs were either incorrectly or not reported, and two students? changes were not reported to NSLDS by the College in a timely manner. In addition, for all 12 applicable students enrolled prior to fall 2019, we noted a gap in their enrollment certification greater than 60 days during summer 2019; for one of those 12 students, a similar instance was noted for summer 2020. 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 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. Also, 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. 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. Questioned Costs: None Context: During our testing, it was noted the College did not have the proper procedures in place in order to ensure the effective enrollment, programs, and status changes and dates reported to NSLDS match the College?s records and are reported timely. It was also noted that enrollment certification was not performed during the summer months. Cause: The College did not have a process in place to ensure the effective date and status reported to NSLDS matches the effective date of the student?s last date of attendance and appropriate reason for change. They also did not have a process in place to report student enrollment and program changes accurately and timely. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. The College also did not comply with Department of Education regulations by reporting student enrollment status changes accurately and timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the College?s last date of attendance. View of Responsible Official: There is no disagreement with the audit finding.
FINDINGS?FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2020-002 NSLDS Reporting CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379 Recommendation: It was recommended the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the College?s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As of April 2020, the Registrar submits monthly updates to the National Student Clearinghouse. In addition to the monthly reporting, term start and end reports are submitted to the National Student Clearinghouse. Name(s) of the contact person(s) responsible for corrective action: Bill Stanfill Planned completion date for corrective action plan: Our first official Enrollment Report to the Clearinghouse was 4/1/2020.
FAC accepted this audit on November 7, 2019 — management decision was due May 7, 2020.
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. Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Questioned Costs: None Context: During our audit procedures, it was noted that the College did not designate an individual to coordinate the information security program; performed 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 documented safeguards for identified risks. Cause: The College has not identified an individual designated to assure compliance with the requirements of the GLBA. The College did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the GLBA. Possible Asserted Effect: Personal information could be vulnerable without safeguards in place. Repeat Finding: No Recommendation: We recommend that the College designate an individual to 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. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019-001: Gramm-Leach-Bliley Act Requirements Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Questioned Costs: None Context: During our audit procedures, it was noted that the College did not designate an individual to coordinate the information security program; performed 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 documented safeguards for identified risks. Cause: The College has not identified an individual designated to assure compliance with the requirements of the GLBA. The College did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the GLBA. Possible Asserted Effect: Personal information could be vulnerable without safeguards in place. Repeat Finding: No Recommendation: We recommend that the College designate an individual to 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. View of Responsible Official: There is no disagreement with the audit finding.
COTTEY COLLEGE CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2019 Department of Education Cottey College respectfully submits the following corrective action plan for the year ended June 30, 2019. Audit period: July 01, 2018 ? June 30, 2019 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS. 2019-001 DEPARTMENT OF EDUCATION Gramm-Leach-Bliley Act Requirements CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379 Recommendation: It was recommended the College designate an individual to 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 Employee training, external penetration testing, and perform an information security risk assessment. Name(s) of the contact person(s) responsible for corrective action: Keith Spencer Planned completion date for corrective action plan: 06/30/2020. If the Department of Education has questions regarding this plan, please call Kim Krokroskia at 417-667-8181 ext. 2106
FAC accepted this audit on November 15, 2017 — management decision was due May 15, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 2, 2016 — management decision was due May 2, 2017.
GSA_MIGRATION
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