EIN: 450306841
UEI: VSCGPLJGN8Z6
Audited by: CapinCrouse LLC
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 December 15, 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 15, 2026 (76 days ago).
What is a management decision? →FAC accepted this audit on January 9, 2025 — management decision was due July 9, 2025.
Students were not appropriately awarded federal direct loans based on need analysis or year of enrollment. Criteria: 34 CFR 685.203 Questioned Costs: $3,000 Context: Out of 37 students tested, 3 were over awarded loans. One student was not awarded aid appropriately based on need analysis; this was corrected by reallocating $2,069 from subsidized to unsubsidized loans. The other two students were incorrectly awarded loans based on their year of enrollment. The first resulted in an over award of $2,000 in unsubsidized loans, and the second was over awarded $1,000 in subsidized loans. Both of these students were corrected during the audit. Because of the percentage of errors in our sample, this is classified as significant. Cause: This was an oversight by the College. Effect: Students received subsidized and unsubsidized federal aid for which they were not eligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College implement a review of aid eligibility to periodically check for over awards. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Ineligible Disbursements Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: Students were not appropriately awarded federal direct loans based on need analysis or year of enrollment. Criteria: 34 CFR 685.203 Questioned Costs: $3,000 Context: Out of 37 students tested, 3 were over awarded loans. One student was not awarded aid appropriately based on need analysis; this was corrected by reallocating $2,069 from subsidized to unsubsidized loans. The other two students were incorrectly awarded loans based on their year of enrollment. The first resulted in an over award of $2,000 in unsubsidized loans, and the second was over awarded $1,000 in subsidized loans. Both of these students were corrected during the audit. Because of the percentage of errors in our sample, this is classified as significant. Cause: This was an oversight by the College. Effect: Students received subsidized and unsubsidized federal aid for which they were not eligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College implement a review of aid eligibility to periodically check for over awards. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after final grades have been posted. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 12/9/2024
Return calculations were not done correctly consistently, particularly in the Fall 2023 semester. Criteria: 34 CFR 668.22 Questioned Costs: $494 Context: Out of 5 withdrawn students, 3 students who withdrew during the audit period tested had incorrect R2T4 calculations. All initial calculations and returns had been performed timely. The system calendar set up for the Fall 2023 semester was done incorrectly leading to the three incorrect calculations. Additionally, two students did not have Federal Supplemental Educational Opportunity Grant (FSEOG) included in the R2T4 calculation, which resulted in total under returns of $438 of Pell and $55 of FSEOG. The third student was only affected by the calendar setup and had an over return of Subsidized Loan in the amount of $22. A full file review was conducted by the College and all students were corrected. Cause: The system calendar setup for the Fall 2023 term was not done correctly, and the exclusion of FSEOG in the R2T4s was an oversight by the College. Effect: Returns of Title IV funds were not performed accurately. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend an individual with appropriate return calculation knowledge review each system set up to ensure the system is functioning as intended, as well as review R2T4 calculations and returns to ensure accuracy and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate Return of Title IV Funds (R2T4) DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, and 84.007 Federal Award Identification #: 2023-2024 Award Year Condition: Return calculations were not done correctly consistently, particularly in the Fall 2023 semester. Criteria: 34 CFR 668.22 Questioned Costs: $494 Context: Out of 5 withdrawn students, 3 students who withdrew during the audit period tested had incorrect R2T4 calculations. All initial calculations and returns had been performed timely. The system calendar set up for the Fall 2023 semester was done incorrectly leading to the three incorrect calculations. Additionally, two students did not have Federal Supplemental Educational Opportunity Grant (FSEOG) included in the R2T4 calculation, which resulted in total under returns of $438 of Pell and $55 of FSEOG. The third student was only affected by the calendar setup and had an over return of Subsidized Loan in the amount of $22. A full file review was conducted by the College and all students were corrected. Cause: The system calendar setup for the Fall 2023 term was not done correctly, and the exclusion of FSEOG in the R2T4s was an oversight by the College. Effect: Returns of Title IV funds were not performed accurately. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend an individual with appropriate return calculation knowledge review each system set up to ensure the system is functioning as intended, as well as review R2T4 calculations and returns to ensure accuracy and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid Office will include weekends in the break days identified in the Return to Title IV schedules created on the COD.gov site. All federal aid will be included in R2T4 calculations. These two issues which came out in the audit were resolved and implemented before the fall 2024 semester. Another person will review the R2T4 form before the process is finalized. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 08/15/2024
FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.
The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We commend the College for all work completed on GLBA. We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We commend the College for all work completed on GLBA. We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address GLBA compliance and is taking steps to address all exceptions noted. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan and Director of IT Matthew Johnson Anticipated Date of Completion: End of fiscal year 2024.
The College did not accurately report certain items relating to Perkins reporting on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The College did not properly report Perkins cash on hand information on the most recent FISAP. Cause: Oversight by management. Effect: FISAP cash on hand was overstated which potentially leads to the College returning more cash to the Department of Education than required. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College work with the Department of Education to correct errors in the Perkins portion of the FISAP. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴FISAP Reporting DEPARTMENT OF EDUCATION ALN #: 84.038 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not accurately report certain items relating to Perkins reporting on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The College did not properly report Perkins cash on hand information on the most recent FISAP. Cause: Oversight by management. Effect: FISAP cash on hand was overstated which potentially leads to the College returning more cash to the Department of Education than required. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College work with the Department of Education to correct errors in the Perkins portion of the FISAP. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporting. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan, Director of Financial Aid Wesley Brothers, and Coordinator of Financial Aid Shannon Pool. Anticipated Date of Completion: CAP has already been implemented regarding this issue.
FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.
During our testing of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, 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 Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 003 ? COD Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268 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 of COD disbursements, CLA noted that 1 out of the 40 selections had a 'COD Applied Date' that was not within 15 days of the 'COD Disbursement Date' Questioned costs: None Context: There was a lack of internal control processes in place for correct reporting to COD. Cause: The College does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, 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 Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-003 COD Reporting Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell 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: Pell disbursements will be reviewed by the Student Aid Coordinator and then by the VP of Student Services to ensure accuracy and timeliness. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Shannon Stoughton, Matt Payne Planned completion date for corrective action plan: This change will take place immediately.
During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. We noted the required quarterly student-portion reporting was not uploaded to the College?s website in fiscal year 2022. We noted the required quarterly institutional-portion reporting for quarter-ending 12/31/21 and 3/31/22 were not uploaded to the College?s website in fiscal year 2022. Lastly, we noted several discrepancies in the numbers reported in the annual report submitted for 2021. There was also no documentation of review of this report. Questioned costs: None Context: There was a lack of internal control processes in place for submission of the necessary required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting or timely submission of reporting. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 004 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425E, 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: The Code of Federal Regulations (CFR) Section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. We noted the required quarterly student-portion reporting was not uploaded to the College?s website in fiscal year 2022. We noted the required quarterly institutional-portion reporting for quarter-ending 12/31/21 and 3/31/22 were not uploaded to the College?s website in fiscal year 2022. Lastly, we noted several discrepancies in the numbers reported in the annual report submitted for 2021. There was also no documentation of review of this report. Questioned costs: None Context: There was a lack of internal control processes in place for submission of the necessary required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting or timely submission of reporting. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-004 Higher Education Emergency Relief Funds (HEERF) Reporting Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reporting will be reviewed for compliance and accuracy by FA Solutions, the student accounts coordinator, student aid coordinator and VP of Student Services. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Melissa Hennessy, Shannon Stoughton and Matt Payne. Planned completion date for corrective action plan: This change will take place immediately.
2021-002
During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: Yes, 2021-003 Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 005 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425F, 84.425M 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: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: Yes, 2021-003 Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022-005 Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procurement Policy put in place in February 2023. Name(s) of the contact person(s) responsible for corrective action: Vaughn Jordan Planned completion date for corrective action plan: Action already in effect.
2021-003
During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022 ? 006 ? Higher Education Emergency Relief Fund (HEERF) ? Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425E, 84.425F, 84.425M 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 Certification and Agreements and/or Supplemental Agreements for CRRSAA HEERF II and ARP HEERF III require that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within three calendar days of the drawdown from G5. Condition: During our testing, we noted 15 student grant payments out of 17 tested which were disbursed outside of the 15-calendar day window. In addition, three institutional expenses out of four tested were disbursed outside of the three-calendar day window. Questioned costs: None Context: The College drew down funds from the Department of Education?s G5 grants system and did not disburse the funds within the necessary timeframe. Cause: The College did not have an internal control structure in place that included reconciling the timing of its expenditures and its G5 drawdowns. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 Higher Education Emergency Relief Fund (HEERF) ? Cash Management Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reporting will be reviewed for compliance and accuracy by FA Solutions, the student accounts coordinator, student aid coordinator and VP of Student Services. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Melissa Hennessy, Shannon Stoughton and Matt Payne Planned completion date for corrective action plan: This change will take place immediately.
FAC accepted this audit on September 25, 2022 — management decision was due March 25, 2023.
During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. Questioned costs: None Context: There was a lack of internal control processes in place for submission of corrections to required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: No Recommendation: We recommend the College correct the required HEERF reporting to align with the revised schedules of expenditures of federal awards. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 002 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425E, 84.425F Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Code of Federal Regulations (CFR) Section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing of reporting, we noted the College did not revise its reporting of the HEERF expenditures that were originally reported in fiscal year 2020 and subsequently corrected on the financial statements of the College. Questioned costs: None Context: There was a lack of internal control processes in place for submission of corrections to required reporting. Cause: The College did not have an internal control structure that included correcting errors in reporting Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: No Recommendation: We recommend the College correct the required HEERF reporting to align with the revised schedules of expenditures of federal awards. Views of Responsible Officials: There is no disagreement with the audit finding.
2021-002 Higher Education Emergency Relief Funds (HEERF) Reporting Recommendation: We recommend the College correct the required HEERF reporting to align with the revised schedules of expenditures of federal awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2023
During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 003 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund ALN: 84.425F and 84.425N Award Period: 2020-2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Universities should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2021-003 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2023
During our testing, we noted 1 student out of 16 tested who was a first time borrower and was disbursed direct loans 23 days after the start of the semester. Questioned costs: None Context: The College disbursed aid without verifying the student was a first time borrower and therefore would need to delay the timing of disbursement. Cause: The College did not have appropriate controls in place to review the student status prior to disbursement. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their process for disbursing to first time borrowers. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 004 ? Student Financial Assistance Cluster ? Disbursement of federal funds to first time borrowers Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN: 84.268 Award Period: 2020-2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: Per federal regulations 34 CFR 668.164(i)(2)), institutions may not disburse or deliver the first installment of Direct Loans to first-year undergraduates who are first time borrowers until 30 days after the student?s first day of classes, unless the institution has a cohort default rate of less than 15% for the last three years. Condition: During our testing, we noted 1 student out of 16 tested who was a first time borrower and was disbursed direct loans 23 days after the start of the semester. Questioned costs: None Context: The College disbursed aid without verifying the student was a first time borrower and therefore would need to delay the timing of disbursement. Cause: The College did not have appropriate controls in place to review the student status prior to disbursement. Effect: The College is out of compliance with this requirement. Repeat finding: No Recommendation: We recommend that the College review their process for disbursing to first time borrowers. Views of responsible officials: There is no disagreement with the audit finding.
2021-004 Student Financial Assistance Cluster Disbursement of federal funds to first time borrowers Recommendation: We recommend that the College review their process for disbursing to first time borrowers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2023
FAC accepted this audit on February 7, 2022 — management decision was due August 7, 2022.
During our testing of reporting, we noted there was no evidence of a formal review or approval occurring prior to the submission and upload of the required documents. Questioned costs: None Context: There was a lack of internal control processes in place for submission of required reporting. Cause: The College did not have an internal control structure that included documented, independent review processes. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: No Recommendation: We recommend the College implement a documented review process for all reporting that is required as part of the federal funding. The review should be completed by a person who is not compiling the report and should be documented appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 002 ? Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds CFDA Numbers: 84.425E, 84.425F Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations (CFR) Section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing of reporting, we noted there was no evidence of a formal review or approval occurring prior to the submission and upload of the required documents. Questioned costs: None Context: There was a lack of internal control processes in place for submission of required reporting. Cause: The College did not have an internal control structure that included documented, independent review processes. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: No Recommendation: We recommend the College implement a documented review process for all reporting that is required as part of the federal funding. The review should be completed by a person who is not compiling the report and should be documented appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.
2020-002 Higher Education Emergency Relief Funds (HEERF) Reporting Recommendation: We recommend the College implement a documented review process for all reporting that is required as part of the federal funding. The review should be completed by a person who is not compiling the report and should be documented appropriately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2022
During our testing, we noted 2 of the 50 students tested were not reported to the Common Origination and Disbursement (COD) system within the required 15 days. Questioned costs: None Context: While performing audit procedures, it was noted that the College did not have proper procedures in place to ensure the timely submission of information to COD. Cause: The College does not have a process in place to accurately report Direct Loan disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to delays in the reporting of disbursements. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 003 ? Common Origination and Disbursement Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster CFDA Numbers: 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 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 2 of the 50 students tested were not reported to the Common Origination and Disbursement (COD) system within the required 15 days. Questioned costs: None Context: While performing audit procedures, it was noted that the College did not have proper procedures in place to ensure the timely submission of information to COD. Cause: The College does not have a process in place to accurately report Direct Loan disbursements to COD within the required 15 days. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to delays in the reporting of disbursements. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2020-003 Common Origination and Disbursement Reporting Recommendation: We recommend the College evaluate its procedures and policies around reporting Direct Loan 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: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2022
During our testing of 40 students, we noted one instance where the program enrollment effective date was improperly reported to NSLDS. Questioned costs: None Context: While performing audit procedures, it was noted that management does not have proper procedures in place specifically to ensure the program enrollment effective date was updated accurately within NSLDS. Cause: The College?s processes and controls did not ensure that program enrollment effective dates were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 004 ? National Students Loan Data System Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 ? Federal Supplemental Education Opportunity Grants 84.033 ? Federal Work Study Program 84.038 ? Federal Perkins Loans 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 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 of 40 students, we noted one instance where the program enrollment effective date was improperly reported to NSLDS. Questioned costs: None Context: While performing audit procedures, it was noted that management does not have proper procedures in place specifically to ensure the program enrollment effective date was updated accurately within NSLDS. Cause: The College?s processes and controls did not ensure that program enrollment effective dates were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
2020-004 National Students Loan Data System Reporting Reporting Recommendation: We recommend the Institute review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2022
During our testing of allowable costs, we noted one disbursement did not qualify as an expenditure to cover costs associated with significant changes to the delivery of instruction due to the coronavirus. The expenditure was a routine expense of the College. Questioned costs: $818 Context: There was a lack of internal control processes in place when compiling expenditures for inclusion in the Schedule of Expenditures of Federal Awards (SEFA). Cause: The College did not have an internal control structure that included documented, independent review processes. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: No Recommendation: We recommend the College implement a documented review process for the preparation of the SEFA. The reviewer should examine the types of expenditures included in the SEFA and the timing of when they were incurred. This review should be completed by a person who is not compiling the schedule and should be documented appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020 ? 005 ? Higher Education Emergency Relief Funds - Unallowable Cost Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds CFDA Numbers: 84.425F Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations (CFR) Section 200.401 requires that nonfederal entities receiving federal awards must use a set of principles to determine the allowable costs of work performed by the nonfederal entity and charged to the federal award. Condition: During our testing of allowable costs, we noted one disbursement did not qualify as an expenditure to cover costs associated with significant changes to the delivery of instruction due to the coronavirus. The expenditure was a routine expense of the College. Questioned costs: $818 Context: There was a lack of internal control processes in place when compiling expenditures for inclusion in the Schedule of Expenditures of Federal Awards (SEFA). Cause: The College did not have an internal control structure that included documented, independent review processes. Effect: Mistakes and/or errors could result if internal control procedures are not properly in place and implemented. Repeat Finding: No Recommendation: We recommend the College implement a documented review process for the preparation of the SEFA. The reviewer should examine the types of expenditures included in the SEFA and the timing of when they were incurred. This review should be completed by a person who is not compiling the schedule and should be documented appropriately. Views of Responsible Officials: There is no disagreement with the audit finding.
2020-005 Higher Education Emergency Relief Funds - Unallowable Cost Recommendation: We recommend the College implement a documented review process for the preparation of the SEFA. The reviewer should examine the types of expenditures included in the SEFA and the timing of when they were incurred. This review should be completed by a person who is not compiling the schedule and should be documented appropriately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A detailed review process will be put in place to ensure all purchases are appropriate for the funding received, all procurement procedures are following established guidelines and the tracking of each purchase is adequately tracked and documented. This process will be implemented through up-level reporting to ensure multiple individuals are ensuring all parameters are met. Reports showing details will be viewable by multiple levels to ensure transparency and accuracy. Schedules will be prepared by the Financial Aid and Business Offices, then reviewed by the Vice President of Finance?s Office. Name(s) of the contact person(s) responsible for corrective action: SaraLi Petersen, Amanda Belmont and Vaughn Jordan. Planned completion date for corrective action plan: 2/1/2022
FAC accepted this audit on November 6, 2019 — management decision was due May 6, 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. Questioned costs: None Context: During our audit procedures, it was noted that the College has not yet 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 is still working towards an IT risk assessment tailored specifically to the College and addressing those risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College complete the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019-002 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.063, 84.007, 84.033, 84.068, 84.268 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the College has not yet 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 is still working towards an IT risk assessment tailored specifically to the College and addressing those risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College complete the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2019-002 Student Financial Aid Cluster ? GLBA Compliance Recommendation: We recommend that the College designate an individual to oversee the information security function, engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Risk Assessment: A risk assessment shall be carried out that will include the three areas identified in 16 CFR 314.4 (b). We shall be using the "Conducting an electronic information risk assessment for Gramm- Leach-Bliley Act Compliance" paper by Kevin Bong as a guide to implementing both the initial and all subsequent risk assessments as well as building the systems for maintaining and reporting on the assessment to the management team. Link to article found here: https://www.sans.org/reading- room/whitepapers/auditing/paper/1053. Name(s) of the contact person(s) responsible for corrective action: Matthew Johnson (IT) has been assigned to oversee the information security function. Planned completion date for corrective action plan: Final report submitted to management team: December 10th, 2019.
Two students out of a sample of 24 were under awarded Pell. Questioned costs: None reported Context: An erroneous computation of the students? eligibility resulted in an under award. Cause: The students? awards were computed using the prior year payment and disbursement schedule. Effect: Two students in our sample were under awarded Pell funds. Repeat Finding: Yes, see finding 2018-001. Recommendation: We recommend that a formal review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019-003 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.063 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. The payment schedules take into account the cost of attendance, the student?s EFC and the enrollment status of the student. Condition: Two students out of a sample of 24 were under awarded Pell. Questioned costs: None reported Context: An erroneous computation of the students? eligibility resulted in an under award. Cause: The students? awards were computed using the prior year payment and disbursement schedule. Effect: Two students in our sample were under awarded Pell funds. Repeat Finding: Yes, see finding 2018-001. Recommendation: We recommend that a formal review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Views of responsible officials: There is no disagreement with the audit finding.
2019-003 Student Financial Aid Cluster ? Pell Awarding Recommendation: We recommend that a formal review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The two (2) students identified in the audit have been updated with the correct amounts. The team lead extracted the FA/ASQ (Detailed Award Status Query) report to identify all students who were paid Pell for the 2018-2019 award year. The internal audit team will use this report to verify that each students? estimated family contribution (EFC) correlates with the Pell amount awarded. We can confirm the correct Pell chart has been updated in the school?s operating platform (Empower) and do not anticipate additional findings. Additionally, all future Pell disbursements will be reviewed by the third party?s internal audit team to ensure no farther reoccurrence of this finding. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Amanda Belmont Planned completion date for corrective action plan: Our completion date of the 2018- 2019 Pell review is November 1, 2019.
2018-001
During the testing of 24 students, it was noted that an incorrect cost of attendance was used when calculating the student aid packages for 17 students. Questioned costs: None reported Context: An erroneous use of the wrong fee schedule caused potential under awards. Cause: The College awarded students using a general fee from the 2017-18 aid year rather than the 2018-19 aid year. The fee increased $50 from the prior year. Effect: Students may not have been fully awarded by this $50, depending on the aid they received or were eligible for. Repeat Finding: No Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019-004 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.007, 84.033, 84.268, 84.063, 84.038 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student?s estimated cost of attendance for the period of enrollment for which the loan is intended less the student?s estimated 2019-004 financial assistance for that period and in the case of Direct Subsidized Loans, the borrower?s expected family contribution for that period. Condition: During the testing of 24 students, it was noted that an incorrect cost of attendance was used when calculating the student aid packages for 17 students. Questioned costs: None reported Context: An erroneous use of the wrong fee schedule caused potential under awards. Cause: The College awarded students using a general fee from the 2017-18 aid year rather than the 2018-19 aid year. The fee increased $50 from the prior year. Effect: Students may not have been fully awarded by this $50, depending on the aid they received or were eligible for. Repeat Finding: No Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Views of responsible officials: There is no disagreement with the audit finding.
2019-004 Student Financial Aid Cluster ? Cost of Attendance Recommendation: We recommend that a process to be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The third-party servicers will collaborate closely with the school to ensure that the Cost of Attendance (COA) amounts are correct and no changes have been made. Additionally, at the start of each new award year the third-party servicer will send out a notification for a review of the upcoming COA amounts. Updates will be made accordingly. .Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Amanda Belmont Planned completion date for corrective action plan: Current
During our testing, we noted that students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Questioned costs: No Context: Direct loan disbursement notifications for the Spring 2019 term were not sent to students within the required time period. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe. Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements. Repeat Finding: No Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019-005 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.268 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts. Condition: During our testing, we noted that students tested did not receive disbursement notifications before the required deadline established by the Department of Education. Questioned costs: No Context: Direct loan disbursement notifications for the Spring 2019 term were not sent to students within the required time period. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe. Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The Institute is not in compliance with Department of Education requirements. Repeat Finding: No Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Views of responsible officials: There is no disagreement with the audit finding.
2019-005 Student Financial Aid Cluster ? Disbursement Notifications Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team lead has changed the process to send out disbursement notifications immediately after disbursing Direct Loan funds. This is a manual process as the schools operating platform does not automatically send them out as other systems do. Part of the internal audit review is to ensure disbursement notifications have been sent out timely. Additionally, all 2019-2020 disbursements will be reviewed by the third party?s internal audit team to ensure this type of issue does not reoccur. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Amanda Belmont Planned completion date for corrective action plan: November 1, 2019 for the 2018- 19 student population. Immediately for the 2019-2020 student population.
During our testing, we noted one student who was awarded the correct dollar amount in total of subsidized and unsubsidized loans. Their award should have been $1,818 of subsidized and $3,682 of unsubsidized loans; however, they were paid $3,500 and $2,000, respectively. Questioned costs: None reported Context: Due to the student?s calculated need, the breakout of loan payments awarded them too much need based aid in the form of unsubsidized loans. Cause: The error was not determined in the payment process and reporting to COD process. The student had been awarded the correct amount of loans in total, but not between categories. Effect: The student received need-based aid when they should not have. Repeat Finding: No Recommendation: We recommend the College review their awarding process to ensure need-based aid is properly awarded. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2019?006 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.268 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student?s estimated cost of attendance for the period of enrollment for which the loan is intended less the student?s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower?s expected family contribution for that period. Condition: During our testing, we noted one student who was awarded the correct dollar amount in total of subsidized and unsubsidized loans. Their award should have been $1,818 of subsidized and $3,682 of unsubsidized loans; however, they were paid $3,500 and $2,000, respectively. Questioned costs: None reported Context: Due to the student?s calculated need, the breakout of loan payments awarded them too much need based aid in the form of unsubsidized loans. Cause: The error was not determined in the payment process and reporting to COD process. The student had been awarded the correct amount of loans in total, but not between categories. Effect: The student received need-based aid when they should not have. Repeat Finding: No Recommendation: We recommend the College review their awarding process to ensure need-based aid is properly awarded. Views of responsible officials: There is no disagreement with the audit finding.
2019-006 Student Financial Aid Cluster ? Stafford Loan Awarding Recommendation: We recommend that the College review their awarding process to ensure need-based aid is properly awarded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The school will ensure before awarding campus- based funds and outside scholarships they notify the team lead to ensure that by adding additional funds it does not create an over award in need-based aid. The third-party servicer will review the 2018-2019 student population to ensure there are no other students who may have been over awarded as a result of additional funding. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Amanda Belmont Planned completion date for corrective action plan: November 1, 2019. If the Department of Education has questions regarding this plan, please call Ian O?Brien at 701-349- 5774.
FAC accepted this audit on October 21, 2018 — management decision was due April 21, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on November 19, 2017 — management decision was due May 19, 2018.
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2016-003
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2016-004
FAC accepted this audit on January 8, 2017 — management decision was due July 8, 2017.
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2015-002
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2015-003
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2015-005
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