EIN: 446001495
UEI: CBCGW61SVPS7
Audited by: KPM CPAs, PC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 4, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 4, 2026 (6 days from today).
What is a management decision? →FAC accepted this audit on January 22, 2025 — management decision was due July 22, 2025.
FAC accepted this audit on January 16, 2024 — management decision was due July 16, 2024.
FAC accepted this audit on January 17, 2023 — management decision was due July 17, 2023.
FAC accepted this audit on January 20, 2022 — management decision was due July 20, 2022.
FAC accepted this audit on January 19, 2021 — management decision was due July 19, 2021.
FAC accepted this audit on January 13, 2020 — management decision was due July 13, 2020.
The District did not have procedures in place to ensure change in enrollment information was accurately being reported to the Department of Education within the required timeframe. Context: A sample of 37 students revealed 23 instances in which the District reported a different graduation date to the National Student Loan Data System (NSLDS) than District records were reporting. A sample of 37 students revealed 6 instances in which the District did not certify specific student data within the required 60 day timeframe to NSLDS. Effect: The District was not in compliance with enrollment reporting to the NSLDS for students who had graduated and the District was not in compliance with the timely reporting requirements for NSLDS reporting. Cause: The District?s policies and procedures did not include proper internal controls over compliance to ensure that these requirements were being met. Questioned costs: The questioned costs are undeterminable and more likely than not would be clearly trivial, and therefore, there are no questioned costs. Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.309 and 34 CFR 682.610 as it relates to the student enrollment status date information reported to the NSLDS and timely reporting requirements. Response: The District was closed approximately two weeks during the 2018-19 school year because of adverse weather conditions. The unusually high number of absences resulted in the adult students having to make up several days of classroom instruction and clinical experience. This caused some confusion in terms of scheduled verses actual graduation dates for the adult student programs. Enrollment reporting to NSLDS is a shared responsibility between Hillyard and Campus Ivy. Hillyard staff will reevaluate and work to improve the process of communicating each student?s last day of attendance to Campus Ivy.
Show full finding ▾Hide full finding ▴U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loan Program CFDA 84.268 Federal Pell Grant Program (PELL) CFDA 84.063 Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.007 2019-003 Student Financial Assistance Cluster ? Special Testing ? Enrollment Reporting Criteria: The U.S. Department of Education requires the District to update changes in student enrollment status, report the date the enrollment status was effective, and submit changes electronically with the National Student Loan Data System (NSLDS) website in accordance with 34 CFR 682.610 and 34 CFR 685.309. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition: The District did not have procedures in place to ensure change in enrollment information was accurately being reported to the Department of Education within the required timeframe. Context: A sample of 37 students revealed 23 instances in which the District reported a different graduation date to the National Student Loan Data System (NSLDS) than District records were reporting. A sample of 37 students revealed 6 instances in which the District did not certify specific student data within the required 60 day timeframe to NSLDS. Effect: The District was not in compliance with enrollment reporting to the NSLDS for students who had graduated and the District was not in compliance with the timely reporting requirements for NSLDS reporting. Cause: The District?s policies and procedures did not include proper internal controls over compliance to ensure that these requirements were being met. Questioned costs: The questioned costs are undeterminable and more likely than not would be clearly trivial, and therefore, there are no questioned costs. Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.309 and 34 CFR 682.610 as it relates to the student enrollment status date information reported to the NSLDS and timely reporting requirements. Response: The District was closed approximately two weeks during the 2018-19 school year because of adverse weather conditions. The unusually high number of absences resulted in the adult students having to make up several days of classroom instruction and clinical experience. This caused some confusion in terms of scheduled verses actual graduation dates for the adult student programs. Enrollment reporting to NSLDS is a shared responsibility between Hillyard and Campus Ivy. Hillyard staff will reevaluate and work to improve the process of communicating each student?s last day of attendance to Campus Ivy.
Findings ? Federal Award Programs Audit Findings 2019-003 to 2019-005 are Compliance Findings relating to the Student Financial Assistance Cluster Finding 2019-006 is a Material Weakness Finding Reference No: 2019-003 Finding Noted: Student Financial Assistance Cluster ? Special Testing ? Enrollment Reporting Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.309 and 34 CFR 682.610 as it relates to the student enrollment status date information reported to the NSLDS and timely reporting requirements. Corrective Action Plan: Enrollment reporting is now a shared responsibility between Hillyard Financial Aid Office and Campus Ivy, the third-party servicer. This relationship has allowed for additional training of employees which will prevent this finding in 2019-20. Implementation Date: June 30, 2019
The District improperly disbursed Direct Student Loan funds exceeding the aggregate loan limits for unsubsidized loans. Context: 1 of the 37 students that we sampled had unsubsidized Direct Student Loan funds disbursed over the aggregate amount of $31,000 for dependent students. Effect: The District was not in compliance with disbursing unsubsidized Direct Student Loan funds within the aggregate limit. Cause: The District?s policies and procedures did not include proper internal controls over compliance to ensure that this requirement was being met. Questioned costs: None, as the over awarded amount has already been refunded to the U.S. Department of Education. Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.203 as it relates to loan limits for Direct Student Loans. . Response: The improper disbursement was an isolated case which is normally prevented within regular processing parameters by the third party processor. Campus Ivy also failed to alert Hillyard staff to the over award. Hillyard is currently monitoring the aggregate subsidized and unsubsidized loan limits of borrowers to safeguard against this error in the future.
Show full finding ▾Hide full finding ▴U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loan Program CFDA 84.268 Federal Pell Grant Program (PELL) CFDA 84.063 Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.007 2019-004 Student Financial Assistance Cluster ? Eligibility Criteria: The U.S. Department of Education limits unsubsidized Direct Student Loans at an aggregate amount of $31,000 for dependent students in accordance with 34 CFR 685.203(e)(1). Condition: The District improperly disbursed Direct Student Loan funds exceeding the aggregate loan limits for unsubsidized loans. Context: 1 of the 37 students that we sampled had unsubsidized Direct Student Loan funds disbursed over the aggregate amount of $31,000 for dependent students. Effect: The District was not in compliance with disbursing unsubsidized Direct Student Loan funds within the aggregate limit. Cause: The District?s policies and procedures did not include proper internal controls over compliance to ensure that this requirement was being met. Questioned costs: None, as the over awarded amount has already been refunded to the U.S. Department of Education. Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.203 as it relates to loan limits for Direct Student Loans. . Response: The improper disbursement was an isolated case which is normally prevented within regular processing parameters by the third party processor. Campus Ivy also failed to alert Hillyard staff to the over award. Hillyard is currently monitoring the aggregate subsidized and unsubsidized loan limits of borrowers to safeguard against this error in the future.
Findings ? Federal Award Programs Audit Findings 2019-003 to 2019-005 are Compliance Findings relating to the Student Financial Assistance Cluster Finding 2019-006 is a Material Weakness Finding Reference No: 2019-004 Finding Noted: Student Financial Assistance Cluster ? Eligibility Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.203 as it relates to loan limits for Direct Student Loans. Corrective Action Plan: Campus Ivy will now alert Hillyard staff to any over awards. Hillyard will also monitor aggregate subsidized and unsubsidized loan limits of borrowers to safeguard against any further errors of this nature in the future. Implementation Date: June 30, 2019.
The District records did not match Common Origination and Disbursement (COD) System actual disbursement dates and amounts. Context: 8 of the 37 students that we sampled had different dates reported to the COD system than what District records reported. Effect: The District was not in compliance with reporting actual disbursement dates and amounts to the COD system. Cause: The District?s policies and procedures did not include proper internal controls over compliance to ensure that this requirement was being met. Questioned costs: None. Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.301(a) as it relates to reporting actual disbursement dates and amounts. Response: Financial reporting guidelines are described in sections 4 and 11 of the Financial Aid Policies and Procedures Manual. Campus Ivy generates a disbursement roster that is used to update COD disbursement dates and amounts. The records are then posted by Hillyard staff, using the same dates and amounts as shown on the roster batch. The ledger postings are subsequently reviewed as part of the monthly reconciliation process. Campus Ivy also performs monthly reconciliations, as well as quarterly random audits of selected student accounts. Any differences discovered when comparing the student ledgers with Campus Ivy internal systems and COD are corrected. Hillyard staff will further examine the process to determine why several individual discrepancies went undetected.
Show full finding ▾Hide full finding ▴U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loan Program CFDA 84.268 Federal Pell Grant Program (PELL) CFDA 84.063 Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.007 2019-005 Student Financial Assistance Cluster ? Reporting ? Financial Reporting Criteria: The U.S. Department of Education requires the District to report actual disbursement dates and amounts in accordance with 34 CFR 685.301(a)(2). Condition: The District records did not match Common Origination and Disbursement (COD) System actual disbursement dates and amounts. Context: 8 of the 37 students that we sampled had different dates reported to the COD system than what District records reported. Effect: The District was not in compliance with reporting actual disbursement dates and amounts to the COD system. Cause: The District?s policies and procedures did not include proper internal controls over compliance to ensure that this requirement was being met. Questioned costs: None. Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.301(a) as it relates to reporting actual disbursement dates and amounts. Response: Financial reporting guidelines are described in sections 4 and 11 of the Financial Aid Policies and Procedures Manual. Campus Ivy generates a disbursement roster that is used to update COD disbursement dates and amounts. The records are then posted by Hillyard staff, using the same dates and amounts as shown on the roster batch. The ledger postings are subsequently reviewed as part of the monthly reconciliation process. Campus Ivy also performs monthly reconciliations, as well as quarterly random audits of selected student accounts. Any differences discovered when comparing the student ledgers with Campus Ivy internal systems and COD are corrected. Hillyard staff will further examine the process to determine why several individual discrepancies went undetected.
Findings ? Federal Award Programs Audit Findings 2019-003 to 2019-005 are Compliance Findings relating to the Student Financial Assistance Cluster Finding 2019-006 is a Material Weakness Finding Reference No: 2019-005 Finding Noted: Student Financial Assistance Cluster ? Reporting ? Financial Reporting Recommendation: We recommend the District implement procedures to strictly comply with requirements of 34 CFR 685.301(a) as it relates to reporting actual disbursement dates and amounts. Corrective Action Plan: Further examination of the process by Hillyard and Campus Ivy will be conducted in order to determine why the process did not catch the individual discrepancies. Processes and procedures will be updated to prevent this issue in the future. Implementation Date: June 30, 2019.
The District?s current policies and procedures that constitute the District?s internal control over compliance allowed noncompliance with various compliance requirements of the Federal Direct Student Loans Program, CFDA No 84.268, the Federal Pell Grant Program, CFDA No 84.063 and the Federal Supplemental Educational Opportunity Grants (FSEOG), CFDA No 84.007, which are parts of the Student Financial Assistance Cluster of programs. These instances of noncompliance have been documented in findings 2019-002 through 2019-005. Criteria: Internal controls over compliance should ensure that the various compliance requirements of each federal program are being met by the District. Effect: Risk is present that instances of noncompliance may occur and not be detected and corrected within a timely period by employees in the normal course of performing their assigned functions. Cause: Current policies and procedures resulted in an insufficient number of adequately trained personnel being involved in the process of meeting various filing and reporting requirements for federal grants. Recommendation: We recommend that the District implement procedures in order to strictly comply with all compliance requirements. Response: The District contracted with Campus Ivy, a third-party servicer, hired an experienced financial aid professional, developed a policies and procedures manual, financial aid handbook, and sent current employees to financial aid training conferences in order to satisfy compliance requirements related to student financial aid administration. SEE SCHEDULE OF FINDINGS AND QUESTED COSTS FOR CHART/TABLE.
Show full finding ▾Hide full finding ▴U.S. Department of Education Federal Direct Student Loans CFDA 84.268 Federal Pell Grant Program (PELL) CFDA 84.063 Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.007 2019-006 Ongoing Monitoring of Compliance with Grant Requirements (REPEAT) Condition: The District?s current policies and procedures that constitute the District?s internal control over compliance allowed noncompliance with various compliance requirements of the Federal Direct Student Loans Program, CFDA No 84.268, the Federal Pell Grant Program, CFDA No 84.063 and the Federal Supplemental Educational Opportunity Grants (FSEOG), CFDA No 84.007, which are parts of the Student Financial Assistance Cluster of programs. These instances of noncompliance have been documented in findings 2019-002 through 2019-005. Criteria: Internal controls over compliance should ensure that the various compliance requirements of each federal program are being met by the District. Effect: Risk is present that instances of noncompliance may occur and not be detected and corrected within a timely period by employees in the normal course of performing their assigned functions. Cause: Current policies and procedures resulted in an insufficient number of adequately trained personnel being involved in the process of meeting various filing and reporting requirements for federal grants. Recommendation: We recommend that the District implement procedures in order to strictly comply with all compliance requirements. Response: The District contracted with Campus Ivy, a third-party servicer, hired an experienced financial aid professional, developed a policies and procedures manual, financial aid handbook, and sent current employees to financial aid training conferences in order to satisfy compliance requirements related to student financial aid administration. SEE SCHEDULE OF FINDINGS AND QUESTED COSTS FOR CHART/TABLE.
Findings ? Federal Award Programs Audit Findings 2019-003 to 2019-005 are Compliance Findings relating to the Student Financial Assistance Cluster Finding 2019-006 is a Material Weakness Finding Reference No: 2019-006 Finding Noted: Ongoing Monitoring of Compliance with Grant Requirements Recommendation: We recommend that the District implement procedures in order to strictly comply with all compliance requirements. Corrective Action Plan: The District contracted with Campus Ivy, a third-party servicer, hired an experience financial aid professional, and sent current employees to financial aid training conferences in order to satisfy compliance requirement related to student financial aid administration. Implementation Date: June 30, 2019.
2018-005
FAC accepted this audit on April 24, 2019 — management decision was due October 24, 2019.
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2017-004
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2017-009
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2017-013
FAC accepted this audit on January 18, 2018 — management decision was due July 18, 2018.
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2016-010
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2016-011
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2016-012
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2016-013
FAC accepted this audit on January 24, 2017 — management decision was due July 24, 2017.
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2015-014
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2015-015
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2015-018
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