EIN: 453912932
UEI: NMWBFNX1UZQ3
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 13, 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 13, 2026 (19 days from today).
What is a management decision? →The College did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $565 Context: Out of 10 students, 2 students who withdrew during the audit period tested had funds returned late. One student had funds returned timely as part of the R2T4 on the student ledger, however was not updated in the Common Origination and Disbursement (COD) and the Grant Management (G5) websites until the audit, resulting in $565 returned late. The other student had $4,503 in unsubsidized loans returned 15 days past the required timeframe. Cause: This was an oversight by the College. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2024-001 Recommendation: We recommend that the financial aid office work closely with their third-party administrator and student accounts office to ensure that funds required to be returned as part of the R2T4 process are being processed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Late Return of Title IV Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants, Federal Direct Student Loans 84.268 Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The College did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $565 Context: Out of 10 students, 2 students who withdrew during the audit period tested had funds returned late. One student had funds returned timely as part of the R2T4 on the student ledger, however was not updated in the Common Origination and Disbursement (COD) and the Grant Management (G5) websites until the audit, resulting in $565 returned late. The other student had $4,503 in unsubsidized loans returned 15 days past the required timeframe. Cause: This was an oversight by the College. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2024-001 Recommendation: We recommend that the financial aid office work closely with their third-party administrator and student accounts office to ensure that funds required to be returned as part of the R2T4 process are being processed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Late Return of Title IV Funds Calculations Planned Corrective Action: We have implemented a document processing system in collaboration with our third-party administrator and the Student Accounts Office to ensure that funds required to be returned as part of the R2T4 process are processed on time. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented
2024-001
The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested for proper NSLDS enrollment status, 2 students had not been reported to NSLDS and were updated as part of the audit. Cause: There was a connectivity issue identified within the student information system (SIS) which prevented the student’s NSLDS enrollment from updating, even though the enrollment appeared to be updated in the SIS. The issue has been resolved, and steps have been taken to ensure it does not occur again in the future. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: 2024-002 Recommendation: We recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year to ensure the SIS flags are operating effectively. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants, 84.268 Federal Direct Student Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested for proper NSLDS enrollment status, 2 students had not been reported to NSLDS and were updated as part of the audit. Cause: There was a connectivity issue identified within the student information system (SIS) which prevented the student’s NSLDS enrollment from updating, even though the enrollment appeared to be updated in the SIS. The issue has been resolved, and steps have been taken to ensure it does not occur again in the future. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: 2024-002 Recommendation: We recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year to ensure the SIS flags are operating effectively. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Report training has been implemented and will continue on an ongoing basis to ensure compliance. We will implement periodic spot checks to prevent this issue from recurring and to ensure that all students are properly enrolled each semester. Person Responsible for Corrective Action Plan: Registrar, Elena Majerowicz Anticipated Date of Completion: Already Implemented
2024-002
Students were not initially appropriately awarded federal loans based on need, eligibility, and enrollment level. Criteria: 34 CFR 685.203, 34 CFR 685.301(a)(4)(ii) Questioned Costs: $6,722 Context: Out of 43 students tested, 6 students were not awarded loans appropriately based on need analysis. One student was over awarded $1,000 in subsidized loans based on enrollment level, another exceeded their aggregate loan limits for subsidized loans by $1,312, and the last exceeded their cost of attendance by $4,410 with the awarding of an unsubsidized loan. There were also three students who were under awarded a combined total of $3,000 in subsidized loans and $2,000 in unsubsidized loans as they were under awarded based on their enrollment level. Cause: For students that were under/over awarded based on enrollment level, it was due to the new student information system that was implemented and automated during fiscal year 2024-2025. The triggers that alert the College’s Financial Aid Office to reassess loan awards following updates by the Registrar’s Office to students’ earned credit hours were not initially activated. These triggers are now enabled, and notifications are being appropriately received. The other students were oversights by the College. Effect: Students received federal loans for which they were not eligible, and students were not awarded federal loans according to eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College continue to complete spot checks to ensure that proper notifications are enabled in the student information system, and that the student award package be reviewed before releasing it for acceptance by the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Students were not initially appropriately awarded federal loans based on need, eligibility, and enrollment level. Criteria: 34 CFR 685.203, 34 CFR 685.301(a)(4)(ii) Questioned Costs: $6,722 Context: Out of 43 students tested, 6 students were not awarded loans appropriately based on need analysis. One student was over awarded $1,000 in subsidized loans based on enrollment level, another exceeded their aggregate loan limits for subsidized loans by $1,312, and the last exceeded their cost of attendance by $4,410 with the awarding of an unsubsidized loan. There were also three students who were under awarded a combined total of $3,000 in subsidized loans and $2,000 in unsubsidized loans as they were under awarded based on their enrollment level. Cause: For students that were under/over awarded based on enrollment level, it was due to the new student information system that was implemented and automated during fiscal year 2024-2025. The triggers that alert the College’s Financial Aid Office to reassess loan awards following updates by the Registrar’s Office to students’ earned credit hours were not initially activated. These triggers are now enabled, and notifications are being appropriately received. The other students were oversights by the College. Effect: Students received federal loans for which they were not eligible, and students were not awarded federal loans according to eligibility. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College continue to complete spot checks to ensure that proper notifications are enabled in the student information system, and that the student award package be reviewed before releasing it for acceptance by the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Planned Corrective Action: System-generated notifications have been implemented within our student information system to flag any academic year changes or required reviews. In addition, a periodic review process of student award packages has been established to ensure funds are awarded accurately and in accordance with applicable awards. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented
FAC accepted this audit on December 2, 2024 — management decision was due June 2, 2025.
When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $3,655 Context: Out of 15 students tested, 5 modular students who withdrew during the audit period tested had funds returned late. All initial calculations were performed timely, however the returns were made 31 to 378 days late. Two of these returns were corrected as part of the audit process. The first student had $686 of Pell returned; the second student had a correction in the return amount - this was corrected by the College for a total of $2,969 in unsubsidized loans returned during the audit. Cause: All initial R2T4 calculations were performed timely by the third party administrator, however there was an oversight by the College when applying the return to the student account. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend that the financial aid office work closely with their third party administrator and student accounts office to ensure that funds required to be returned as part of the R2T4 process are being processed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate and Untimely Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $3,655 Context: Out of 15 students tested, 5 modular students who withdrew during the audit period tested had funds returned late. All initial calculations were performed timely, however the returns were made 31 to 378 days late. Two of these returns were corrected as part of the audit process. The first student had $686 of Pell returned; the second student had a correction in the return amount - this was corrected by the College for a total of $2,969 in unsubsidized loans returned during the audit. Cause: All initial R2T4 calculations were performed timely by the third party administrator, however there was an oversight by the College when applying the return to the student account. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend that the financial aid office work closely with their third party administrator and student accounts office to ensure that funds required to be returned as part of the R2T4 process are being processed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid team will continue to work R2T4s as the pertinent information of the drop/withdraw is received from the Academic team. Once notification is received from the Academic department, the Third-Service provider will review and make timely requests for additional documentation to ensure the calculations and returns are completed in a timely manner, based off the requested information needed. Both the Financial Aid and Student Accounts departments will work in conjunction with the Third-Service provider to ensure timely changes reflect on the student’s ledger. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action
2023-004
The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested for proper NSLDS enrollment status, 2 students had not been reported to NSLDS, 1 student had not been properly reported as graduated to NSLDS, and 3 students had not been properly reported as withdrawn to NSLDS. All 6 students were updated during the audit process. Cause: A new update to the student information system had caused it to have issues processing NSLDS changes timely. The College is currently working with the student information system support to ensure the issue is resolved. Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College put a system in place to ensure that enrollment is reported timely and accurately while the student information system issue is resolved. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year to ensure appropriate reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested for proper NSLDS enrollment status, 2 students had not been reported to NSLDS, 1 student had not been properly reported as graduated to NSLDS, and 3 students had not been properly reported as withdrawn to NSLDS. All 6 students were updated during the audit process. Cause: A new update to the student information system had caused it to have issues processing NSLDS changes timely. The College is currently working with the student information system support to ensure the issue is resolved. Effect: Inaccurate reporting can impact a student's loan grace period, in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College put a system in place to ensure that enrollment is reported timely and accurately while the student information system issue is resolved. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year to ensure appropriate reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: With new automation we have more timely notifications when students have been dropped. The Pillar Financial Aid department has updated policies and procedures to monitor the withdrawal process to inform the Registrar’s office, which will ensure the necessary changes to the NSLDS record are made in a timely manner. Person Responsible for Corrective Action Plan: Christine Schroeder, Assistant VP of Enrollment Services Anticipated Date of Completion: Current action
FAC accepted this audit on June 12, 2024 — management decision was due December 12, 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 implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. 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 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 Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 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 implemented an Information Security Program, sufficiently documented its security risk assessment and safeguards, including general threats, implemented multi-factor authentication on systems containing personally identifiable information (PII), or fully implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews. 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 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: The GLBA Information Security document will be updated to reflect the February 2023 changes. Person Responsible for Corrective Action Plan: Washington Ricardo Izquierdo, Senior Director of Information Technology Anticipated Date of Completion: May 31, 2024.
The College disbursed various federal financial assistance an ineligible student and to students who did not begin attendance in all the classes in the term for which the Title IV aid was disbursed. The College is to return Title IV aid within 30 days when the student fails to begin attendance. Criteria: 34 CFR 668.21 Questioned Costs: $9,276 Context: Out of 15 withdrawal students tested for proper aid disbursement, there were 9 for whom the College did not timely adjust the student’s aid based on their attendance records. This resulted in $12,661 of Pell and $13,857 of Federal Direct Loans (FDL) returned late to the Department of Education ranging from 54 to 264 days. As of the of the end of the audit, $9,571 of Pell and $7,671 FDL were returned to the Department of Education. Cause: There was a lack of communication between the Registrar and the Financial Aid Office when the students did not begin attendance. Professors did not provide confirmation of attendance timely to the Registrar. Effect: Students where disbursed aid for which they were ineligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College develop a process for communicating attendance changes in a timely manner between offices. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Disbursements to Ineligible Students Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, and 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College disbursed various federal financial assistance an ineligible student and to students who did not begin attendance in all the classes in the term for which the Title IV aid was disbursed. The College is to return Title IV aid within 30 days when the student fails to begin attendance. Criteria: 34 CFR 668.21 Questioned Costs: $9,276 Context: Out of 15 withdrawal students tested for proper aid disbursement, there were 9 for whom the College did not timely adjust the student’s aid based on their attendance records. This resulted in $12,661 of Pell and $13,857 of Federal Direct Loans (FDL) returned late to the Department of Education ranging from 54 to 264 days. As of the of the end of the audit, $9,571 of Pell and $7,671 FDL were returned to the Department of Education. Cause: There was a lack of communication between the Registrar and the Financial Aid Office when the students did not begin attendance. Professors did not provide confirmation of attendance timely to the Registrar. Effect: Students where disbursed aid for which they were ineligible. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College develop a process for communicating attendance changes in a timely manner between offices. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Disbursements to Ineligible Students Planned Corrective Action: With the new automation process we have exceptions that will prevent the funding from posting if there is no LDA listed. We have also updated the Disbursement Criteria Approval to help prevent inaccurate disbursements from posting. Person Responsible for Corrective Action Plan: Ingrid Ortiz, Director of Financial Aid Anticipated Date of Completion: Implemented as of Fall 2023.
When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 14 modular students tested, the College returned Title IV funds for one student withdrawal that did not require funds to be returned based on the completion rate. Additionally, there was one student who had a return that was 262 days late. Cause: There was no timely review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate and Untimely Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 14 modular students tested, the College returned Title IV funds for one student withdrawal that did not require funds to be returned based on the completion rate. Additionally, there was one student who had a return that was 262 days late. Cause: There was no timely review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: With new automation we have more timely notifications on when students have been dropped. The Pillar Financial Aid department has updated their policies to monitor the withdrawal calculations to ensure they are completed within the allotted timeframe. Person Responsible for Corrective Action Plan: Ingrid Ortiz, Director of Financial Aid Anticipated Date of Completion: Implemented as of Spring 2024.
2022-003
Students were not properly awarded Pell. Criteria: 34 CFR 690.63(b) Questioned Costs: $13 Context: Out of 42 students tested, 2 student were not disbursed aid for all the classes they attended in a term resulting in $3,091 under award of Pell. 1 student was inadvertently over awarded Pell by $13. Cause: Changes in enrollment status were not caught. Effect: There was an incorrect amount of Pell paid to these two students. Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. We recommend that attendance in each module be confirmed by an academic related activity and financial aid office be notified so that appropriate changes to Pell awards can be made timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not properly awarded Pell. Criteria: 34 CFR 690.63(b) Questioned Costs: $13 Context: Out of 42 students tested, 2 student were not disbursed aid for all the classes they attended in a term resulting in $3,091 under award of Pell. 1 student was inadvertently over awarded Pell by $13. Cause: Changes in enrollment status were not caught. Effect: There was an incorrect amount of Pell paid to these two students. Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. We recommend that attendance in each module be confirmed by an academic related activity and financial aid office be notified so that appropriate changes to Pell awards can be made timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations Planned Corrective Action: Per our policies we will work in conjunction with Academics to ensure timely response in updating Pell based enrollment changes. Tasks will be generated to ensure both groups are reviewing in a timely manner. Person Responsible for Corrective Action Plan: Ingrid Ortiz, Director of Financial Aid Anticipated Date of Completion: Implemented as of Fall 2023.
2022-006
The College is required to pay out credit balances created by federal aid within 14 days of the balance being created. Additionally, they are not allowed to hold credit balances beyond the end of the payment period. Criteria: 34 CFR 668.164(h) Questioned Costs: $0 Context: Out of 40 students tested for holding credit balances, there were 3 students who had a credit balance created by Federal Direct Loans and Federal Pell that were not paid out to the student before the end of the payment period. These were corrected during the course of the audit. Cause: There was not a process in place to identify credit balances created by federal aid within the 14 day time frame and again at the end of the payment period. Effect: Noncompliance with the Department of Education's cash management regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College design and implement a process to identify credit balances created by federal aid and disburse them to students within 14 days of the balance being created and to pay out all credit balances at the end of the payment period. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Credit Balances Held Beyond Payment Period DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College is required to pay out credit balances created by federal aid within 14 days of the balance being created. Additionally, they are not allowed to hold credit balances beyond the end of the payment period. Criteria: 34 CFR 668.164(h) Questioned Costs: $0 Context: Out of 40 students tested for holding credit balances, there were 3 students who had a credit balance created by Federal Direct Loans and Federal Pell that were not paid out to the student before the end of the payment period. These were corrected during the course of the audit. Cause: There was not a process in place to identify credit balances created by federal aid within the 14 day time frame and again at the end of the payment period. Effect: Noncompliance with the Department of Education's cash management regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the College design and implement a process to identify credit balances created by federal aid and disburse them to students within 14 days of the balance being created and to pay out all credit balances at the end of the payment period. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Credit Balances Held Beyond Payment Period Planned Corrective Action: Per our policies, accounts are reviewed weekly and credit balances are processed within the 14-day period. Person Responsible for Corrective Action Plan: Ingrid Ortiz, Director of Financial Aid Anticipated Date of Completion: Implemented as of Spring 2024.
FAC accepted this audit on August 13, 2023 — management decision was due February 13, 2024.
The College did not report enrollment information to the National Student Loan Data System (NSLDS) accurately. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 19 students had been reported to NSLDS correctly as enrolled at the program level but reported as withdrawn at the campus level. Cause: It was discovered in March 2023 that the student information system was incorrectly processing the NSLDS Enrollment reporting. The College has a file of all students that need to be updated and corrected, which will be processed this summer. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the College spot check students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) accurately. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 60 students tested, 19 students had been reported to NSLDS correctly as enrolled at the program level but reported as withdrawn at the campus level. Cause: It was discovered in March 2023 that the student information system was incorrectly processing the NSLDS Enrollment reporting. The College has a file of all students that need to be updated and corrected, which will be processed this summer. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the College spot check students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Enrollment Reporting to NSLDS Planned Corrective Action: The college will continue to process the semi-monthly NSLDS reporting through the SIS and undertake spot checking 10% of the reported students after each enrollment reporting submission is completed to ensure accurate enrollment reporting. The errors will be fixed, and the type of errors will be tracked to modify the SIS as needed. Person Responsible for Corrective Action Plan: Brian Schroeder, Registrar Anticipated Date of Completion: current
When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Inaccurate and Untimely Returns to Title IV (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.007, 84.063 and 84.268 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew from a term either officially or unofficially, the College did not always return unearned Title IV aid timely or accurately. Criteria: 34 CFR 668.22 Questioned Costs: $19,131 Context: Out of 12 students tested, 6 students did not have R2T4?s completed timely in the amount of $20,672 returned late ranging from 39 to 422 days late. 5 of these were corrected in March 2023 as part of the audit process. 2 of the 6 students also had incorrect R2T4?s completed due to incorrect funds disbursed and number of days in the term resulting in an additional $42 in federal direct loans, $62 in Pell and $62 in FSEOG to be returned. Cause: There is no review being completed at the end of each term of students with federal aid and no passing grades to determine if an R2T4 is required. Effect: Return of Title IV funds were not performed timely and accurately. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. We also recommend that the financial aid office review all students with federal aid and no passing grades at the end of each term to ensure that if an R2T4 is required, it is completed timely. With multiple calendars used in R2T4 calculations, we recommend that a secondary review be completed when the R2T4 templates are set up to ensure the correct number of days are used in the calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate and Untimely Returns to Title IV Planned Corrective Action: Pillar College changed the R2T4 policy in the catalog and created an R2T4 form to monitor the process. Our operating system, Anthology, has been upgraded to include automatic triggers. The automated system alerts financial aid, the third-party servicer and the registrar to process and critique the effects of the student?s official and/or unofficial withdrawal. Three specific processes have been created and are combined under ?Withdrawal Process Flow Charts: Official, Unofficial and Non-Returning Student?. After analysis the financial aid office and third-party servicer determine the potentiality of funds to be returned to Title IV in a timely manner. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Officer Anticipated Date of Completion: current
2021-002
A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Satisfactory Academic Progress (SAP) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.007, 84.033, 84.063, 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: A student not making SAP was disbursed aid without an approved appeal. Criteria: 34 CFR 668.34(c) Questioned Costs: $3,373 Context: Out of the 10 students not making SAP in 21-22, 1 student should have had an appeal after the fall 2021 term in order to be eligible for the Spring 2022 disbursement. This student was the only one who had a warning status from the Spring 2021 and attended the entire year. The other 9 students had 1 semester warning and then suspension after the 21-22 financial aid year. Cause: Turnover in staffing. Students put on SAP warning were not evaluated after each term. Effect: Ineligible students disbursed federal aid. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the financial aid office and registrar's office work together to ensure SAP is properly monitored after each term to ensure only eligible students are awarded federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Satisfactory Academic Progress Planned Corrective Action: To receive financial aid students must maintain a cumulative grade point average (GPA) of 2.0 (?C?) or better, or be in a SAP-Probation program to recover their GPA. Pillar College academic standards require a student to have a minimum of a 2.0 cumulative Grade Point Average (GPA) to graduate. Degree seeking students will be evaluated for Satisfactory Academic Progress (SAP) on an annual basis. Pillar College is dedicated to helping students succeed academically and progress to graduation and is therefore committed to identifying students who may be struggling. Satisfactory Academic Progress is measured by three components: 1) The student?s cumulative grade point average (CGPA), 2) The student?s rate of progress toward completion (ROP), and 3) The maximum time frame (MTF) allowed to complete the academic program. (150% for all programs.) All students who receive financial aid at Pillar College are required to meet qualifying Academic standards. The student must maintain Satisfactory Academic Progress (SAP). If a student?s cumulative GPA falls below a 2.0, the student will be placed in Suspension Pending and must appeal to remain in school. Upon review of the appeal, the student will be placed on SAP Probation for the following semester/year and directed to the Academic Resource Center (ARC) for mandatory tutoring sessions through registration into ARC-090 SAP Remediation, a pass/fail course for SAP students. For the LEAD Program, the GPA benchmark is 2.5 to remain in the program. The probationary status permits the student to continue in college while working with the Academic Resource Center (ARC) to address deficiencies and take corrective action for improvement. The student may continue to receive Title IV and State Financial Aid so long as they are adhering to their SAP Remediation Plan. The student must use the SAP Remediation Form while on SAP Probation (available from the ARC). An assessment of current enrolled students? degree progress will occur mid-July. If the SAP standard is not being met, the student will be placed on SAP-Probation. It is possible to continue to receive Financial Aid while on SAP-Probation if the student?s ?Academic Plan? is being followed, and grades are improving. If a student does not adhere to the ?Academic Plan?, they may be moved to SAP-Suspension, and removed from the financial aid program. Aid will also be suspended for the semester if credit hours attempted fall below the credit hour criteria. Pillar College financial aid office, the Academic Resource Center (ARC) and the registrar?s office met to discuss and update the Satisfactory Academic Policy (SAP policy), implementing the changes in the current fiscal year. These changes are reflected in the Pillar College Catalog. Due to upgraded student services systems the process is functioning more effectively and efficiently. As stated before, an assessment of current enrolled students? degree progress will occur mid-July. The registrar, financial aid, and the Academic Resource Center (ARC) will meet together as a team two days after the report is published to discuss the results. Students will be notified individually through phone calls and emails to make an appointment with the Academic Resource Center to create a self-evaluative plan to increase their GPA. The ARC will upload the plan into the student services system and monitor the student?s progress by direct contact with the student. It will be noted in the student services system under the individual student?s account if a student does not respond to the notices, phone calls or emails that are sent. The student will be put on academic hold and will not be able to enroll in the new semester. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Office Anticipated Date of Completion: current
Students were not initially awarded subsidized aid based on need. Criteria: 34 CFR 668.42 & 34 CFR 685.301 Questioned Costs: $0 Context: Out of 60 students, 3 students were not awarded aid appropriately based on need analysis. 2 students received unsubsidized loans when they were eligible for subsidized loan totaling $1,564 under awarded. 1 student was awarded $3,765 subsidized loans in excess of need due to institutional scholarships excluded from estimated financial assistance. Cause: No secondary review of awarding. Effect: Students not awarded need based federal aid according to eligibility. Incorrect allocation of subsidized versus unsubsidized loans affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the College or their third-party administrator set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 21-22 Financial Aid Year Condition: Students were not initially awarded subsidized aid based on need. Criteria: 34 CFR 668.42 & 34 CFR 685.301 Questioned Costs: $0 Context: Out of 60 students, 3 students were not awarded aid appropriately based on need analysis. 2 students received unsubsidized loans when they were eligible for subsidized loan totaling $1,564 under awarded. 1 student was awarded $3,765 subsidized loans in excess of need due to institutional scholarships excluded from estimated financial assistance. Cause: No secondary review of awarding. Effect: Students not awarded need based federal aid according to eligibility. Incorrect allocation of subsidized versus unsubsidized loans affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the College or their third-party administrator set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Planned Corrective Action: The Pillar College financial aid office and third-party servicer utilizes the upgraded automated student information system to assess each student?s remaining need based on the Cost of Attendance Budget minus the total funding received from federal, state, and institutional scholarships. Triggers within the system are generated to the financial aid department when a student?s financial eligibility for packaging changes. Changes occur when the student?s enrollment status is reassessed and modified, or when their credits have increased after transfer credits have been entered into the system. Periodic reports will be set up in the student information system to check for over or under awarding of need based federal aid. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Officer Anticipated Date of Completion: current
2 students out of 41 tested were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $612 Context: 1 student was disbursed Pell based on full time enrollment but the student only attended halftime resulting in a $612 Pell over awarded for a term. 1 student was only disbursed for halftime enrollment but attended fulltime resulting in a $1,624 Pell under awarded for a term. Cause: Changes in enrollment status not caught Effect: Students not disbursed Pell awards for which they were eligible. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that a review of Pell awards based on enrollment status be completed after each term to ensure that enrollment changes are captured and Pell adjusted accordingly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: 2 students out of 41 tested were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $612 Context: 1 student was disbursed Pell based on full time enrollment but the student only attended halftime resulting in a $612 Pell over awarded for a term. 1 student was only disbursed for halftime enrollment but attended fulltime resulting in a $1,624 Pell under awarded for a term. Cause: Changes in enrollment status not caught Effect: Students not disbursed Pell awards for which they were eligible. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that a review of Pell awards based on enrollment status be completed after each term to ensure that enrollment changes are captured and Pell adjusted accordingly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Pell Calculations Planned Corrective Action: The Pillar College financial aid office and third-party servicer utilizes the upgraded automated student information system that triggers an activity when a student?s enrollment status has increased to full time or lessened from their initial enrollment status. Reports will be run to ensure the enrollment changes are captured and Pell is adjusted accordingly. Person Responsible for Corrective Action Plan: Betzi Schroeder, Financial Aid Office Anticipated Date of Completion: current
The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Federal Procurement Requirements for Higher Education Stabilization Fund (HEERF) DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: The College did not follow federal procurement requirements when making purchasing decisions with HEERF funds. Criteria: 2 CFR 200.318 through 200.327 Questioned Costs: $0 Context: While the expenditures tested as part of the audit met allowable cost requirements, minimum federal procurement requirements were not followed. The majority of expenditures were related to updating technology and curriculum for offering distance education classes. Cause: Turnover in staffing. Current personnel were unfamiliar with the federal procurement requirements. Effect: Noncompliance with Uniform Guidance regulations that could impact future funding opportunities. Identification as repeat finding, if applicable: Not applicable. Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College update their policies to include procurement standards in the event that future federal grants are received Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Federal Procurement Requirements for Higher Education Stabilization Fund Planned Corrective Action: A policy addressing procurement standards has been created and will be implemented for future expenditures Person Responsible for Corrective Action Plan: Cindy L Weaver, Interim CFO/Director of Finance Anticipated Date of Completion: July 25, 2023
While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Higher Education Stabilization Fund (HEERF) Reporting DEPARTMENT OF EDUCATION ALN #: 84.425F and 84.425L Federal Award Identification #: P425F204061 and P425L200175 Condition: While the College posted the HEERF institutional quarterly reports to the College?s website, the reports were not accurate. Criteria: 2 CFR 200.329, 86 FR 26213 Questioned Costs: $0 Context: During the audit, it was noted that quarterly reporting did not agree to the College records for the institutional funds expended nor was the minority serving institution fund expenditures reported. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: Not applicable Recommendation: As the College expended all HEERF funding as of June 30, 2022, we recommend that the College post corrected quarterly reports to their website. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Higher Education Stabilization Fund (HEERF) Reporting Planned Corrective Action: Corrected quarterly reports will be completed and the practice will be maintained for any future funding received. Person Responsible for Corrective Action Plan: Cindy L. Weaver, Interim CFO/Director of Finance Anticipated Date of Completion: July 25, 2023
FAC accepted this audit on August 23, 2022 — management decision was due February 23, 2023.
When students withdrew from the term, the College did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students tested, 3 students had a total of $1,841 in Pell funds returned late, ranging from 14 to 18 days. Cause: COVID-19, turn over in staffing. Effect: Return of Title IV funds were not performed timely. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2020-2021 Financial Aid Year Condition: When students withdrew from the term, the College did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students tested, 3 students had a total of $1,841 in Pell funds returned late, ranging from 14 to 18 days. Cause: COVID-19, turn over in staffing. Effect: Return of Title IV funds were not performed timely. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the financial aid office work closely with the registrar office and their third party administrator to ensure that R2T4s are completed timely when students cease attendance during the term. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-002 Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: To ensure timely returns of Title IV funds, the academic/registrar office will be providing course withdrawal information as soon as it is aware of the student?s course withdrawals. For students who do not officially inform the college of their decision to withdraw, the student?s participation will be reviewed at the end of the scheduled term to confirm the student?s participation. Additionally, any missing grades or attendance postings will be requested from faculty. Upon confirming a student?s course withdrawal, an activity will be assigned in Anthology Student system to our third-party servicer ? FA Solutions LLC. The third-party servicer will review the student?s information to determine whether or not the student is in fact a withdrawal from the program/institution. Financial Aid at Pillar will work with the third-party servicer to confirm those students who require an R2T4 be completed. When a calculation is required, the college will request an R2T4 be completed for the withdrawn student. This request will be provided to the third-party servicer to process and complete the R2T4 calculation and any returns or PWDs that result from that calculation. This process will ensure more accurate and timely returns. Person Responsible for Corrective Action Plan: Alexandra Madrigal, FA Director Anticipated Date of Completion: Implemented
FAC accepted this audit on March 25, 2021 — management decision was due September 25, 2021.
The College did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not documented its security assessment. Cause: The College has not allocated sufficient resources to address 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. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-002 Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2019-2020 Financial Aid Year Condition: The College did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not documented its security assessment. Cause: The College has not allocated sufficient resources to address 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. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2020-002 Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The outlined Student Financial Aid Information Risk Assessment depicts the steps and specific actions that Pillar College is making in reference GLBA. Person Responsible for Corrective Action Plan: Michael Shields Anticipated Date of Completion: March 18, 2021 with ongoing reviews and updates
Enrollment status was not always reported accurately to the National Student Loan Data Service (NSLDS) Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: Out of 64 students tested for accurate enrollment reporting to NSLDS, 2 students who began attending the College in the spring 2020 term, were not reported to NSLDS as enrolled at Pillar. 1 of these students was subsequently reported as enrolled full time but with an effective date of August 2020 rather than January 2020 when the student actually began attendance. Cause: Registrar system does not appear to be pulling correct enrollment data for all students. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning of loan repayment, appropriate interest charges, etc. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the registrar's office work with the IT department to determine the underlying cause. We also recommend that there be periodic reviews to spot check accuracy by doing a reconciliation between your student information system and NSLDS. There are various enrollment reports that can be requested from NSLDS to aid in this process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-003 NSLDS Reporting DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 2019-2020 Financial Aid Year Condition: Enrollment status was not always reported accurately to the National Student Loan Data Service (NSLDS) Criteria: 34 CFR 685.309(b) Questioned Costs: $-0- Context: Out of 64 students tested for accurate enrollment reporting to NSLDS, 2 students who began attending the College in the spring 2020 term, were not reported to NSLDS as enrolled at Pillar. 1 of these students was subsequently reported as enrolled full time but with an effective date of August 2020 rather than January 2020 when the student actually began attendance. Cause: Registrar system does not appear to be pulling correct enrollment data for all students. Effect: Inaccurate reporting of enrollment status and effective dates can impact a student?s grace period, in school deferment eligibility, beginning of loan repayment, appropriate interest charges, etc. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the registrar's office work with the IT department to determine the underlying cause. We also recommend that there be periodic reviews to spot check accuracy by doing a reconciliation between your student information system and NSLDS. There are various enrollment reports that can be requested from NSLDS to aid in this process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is addressing the issue. See corrective action plan.
Finding Number: 2020-003 NSLDS Reporting Planned Corrective Action: The two records were corrected manually at the NSLDS and the school will spot check accuracy moving forward. The reporting mechanism was not capturing all data correctly and we are working within the database to ensure the NSLDS Enrollment Report is processing all data correctly. Person Responsible for Corrective Action Plan: Brian Schroeder, Registrar Anticipated Date of Completion: March 2021
FAC accepted this audit on March 24, 2020 — management decision was due September 24, 2020.
The College did not return unearned Title IV funds timely. Criteria: 34 CFR 668.22 (e) Questioned Costs: $6,224 Context: Out of 8 students tested, 2 did not have Title IV funds returned timely. 1 return of $6,744 in federal direct loans was 15 days late and 1 return of $1,622 in federal direct loans was 70 days late. 2 students stopped attending prior to the end of the payment period but no R2T4 was calculated. 1 student didn?t have unearned Title IV returned. 1 student had her aid for the term disbursed after she stopped attending but it was more than she was eligible for as a post withdraw disbursement. Effect: Unearned Title IV funds were not returned as required. Cause: Complexity of Department of Education regulations regarding R2T4?s for modular programs and therefore, the third party administrator (TPA) who completes the R2T4 calculation was not notified of the 2 students in a modular program who stopped attending before the end of the payment period. For the 2 students who did have R2T4?s calculated, the TPA was not notified timely of the withdraws and therefore, the returns were late. Identification as repeat finding, if applicable: Yes, 2018-002 Recommendation: We recommend that the College work with the registrar?s office and the TPA to put procedures in place to identify and notify the TPA of students who completely withdraw before completing a term and require an R2T4. We also recommend that procedures be put in place to ensure that once an R2T4 calculation has been completed, the unearned Title IV aid is returned to DOE within the required 45 days. Views of Responsible Officials: Management is in agreement with the finding and is in the process of correcting the issue, see corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 Untimely Return of Unearned Title IV Funds Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.063 and 84.268 Federal Award Identification #: 18/19 Financial Aid Year Condition: The College did not return unearned Title IV funds timely. Criteria: 34 CFR 668.22 (e) Questioned Costs: $6,224 Context: Out of 8 students tested, 2 did not have Title IV funds returned timely. 1 return of $6,744 in federal direct loans was 15 days late and 1 return of $1,622 in federal direct loans was 70 days late. 2 students stopped attending prior to the end of the payment period but no R2T4 was calculated. 1 student didn?t have unearned Title IV returned. 1 student had her aid for the term disbursed after she stopped attending but it was more than she was eligible for as a post withdraw disbursement. Effect: Unearned Title IV funds were not returned as required. Cause: Complexity of Department of Education regulations regarding R2T4?s for modular programs and therefore, the third party administrator (TPA) who completes the R2T4 calculation was not notified of the 2 students in a modular program who stopped attending before the end of the payment period. For the 2 students who did have R2T4?s calculated, the TPA was not notified timely of the withdraws and therefore, the returns were late. Identification as repeat finding, if applicable: Yes, 2018-002 Recommendation: We recommend that the College work with the registrar?s office and the TPA to put procedures in place to identify and notify the TPA of students who completely withdraw before completing a term and require an R2T4. We also recommend that procedures be put in place to ensure that once an R2T4 calculation has been completed, the unearned Title IV aid is returned to DOE within the required 45 days. Views of Responsible Officials: Management is in agreement with the finding and is in the process of correcting the issue, see corrective action plan.
Finding Number: 2019-001 Untimely Return of Unearned Title IV Funds Planned Corrective Action: Pillar College has implemented a corrective plan to confirm student drops to be processed in an accurate, timely fashion within the Campus Nexus software system. Pillar College reviewed the processes set in place during last year?s audit and has implemented further automation connecting the college?s notifications for withdraws from students with the college?s need to alert FA Solutions in a timely fashion for R2T4 processing.. Pillar College has centered the process for withdraws within its Student Service Center area, a group responsible for daily contact and support for students. The group ensures the student receives FA Counseling prior to withdrawing to understand potential implications of the process. The Student Service Center uploads the withdraw form to Campus Nexus. The form upload triggers automatic notification to the Registrar?s Office to process. The change of the student status from Active to Withdraw automatically triggers the Director of FA and FA Solutions to process the withdraw. The activities are reviewed weekly to ensure they are processed on time. The R2T4 calculation is processed in accordance with the federal guidelines and funds reduced in COD as applicable. The third-party servicer will notify the college of any Title IV funds that need to be returned. Funds are moved from the schools operating account to the G5 account where the Third Party will complete the return(s) as applicable through G5. The Third Party will send the college a roster as notification of returns and the college will post funds accordingly. Person Responsible for Corrective Action Plan: Keyla Pavia (Chief of Staff), Rupert Hayles (COO), Betzi Schroeder (Financial Aid Director), Christine Schroeder (Director of Student Service Center), Brian Schroeder (Registrar), FA Solutions, Tashorna Montgomery (Director of Student Accounts) Anticipated Date of Completion: 3/30/2020
2018-002
FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.
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