EIN: 460280847
UEI: JBRHEEGWNG61
Audited by: EIDE BAILLY LLP
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 12, 2023. 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 12, 2024 (812 days ago).
What is a management decision? →During testing over the eligibility requirements, the following deficiencies were noted: •2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862. •7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need. •5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need. Effect: Students were not awarded the proper amount of aid. Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880. Repeat Finding from Prior Year(s): Yes. Recommendation: Based on the announced College closure, we recommend the students with errors be corrected. Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program CFDA # 84.063 – Federal Pell Grant Program 2022-2023 Award Year Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Material Weakness in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program. Condition: During testing over the eligibility requirements, the following deficiencies were noted: •2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by$2,773 and one was over awarded by $862. •7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were underawarded subsidized loans based on being awarded as the wrong academic year in school; and 3 studentswere over awarded subsidized loans as the students did not have financial need. •5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students witherrors were under awarded unsubsidized loans based on being awarded as the wrong academic year inschool. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of determining the student aid throughout the year. Along with this, the College determined that errors in the software they were using to determine student aid were causing issues with over awarding when students did not have financial need. Effect: Students were not awarded the proper amount of aid. Questioned Costs: Pell error: $1,911 under awarded; Direct subsidized Loans: $3,952 under awarded and $6,185 over awarded; Direct unsubsidized Loans: $5,940 under awarded. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $144,700 and Direct loans of $359,880. Repeat Finding from Prior Year(s): Yes. Recommendation: Based on the announced College closure, we recommend the students with errors be corrected. Views of Responsible Officials: Management agrees with the finding. Management has reviewed the errors and made corrections as needed.
Finding 2023-003 Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: • 2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by $2,773 and one was over awarded by $862. • 7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being awarded as the wrong academic year in school; and 3 students were over awarded subsidized loans as the student did not have financial need. • 5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students with errors were under awarded unsubsidized loans based on being awarded as the wrong academic year in school. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The College has reviewed all students impacted by the errors noted above and made corrections to the students as needed. Anticipated Completion Date: September 30, 2023
2022-002
When testing cash management related to reconciliations, we noted the following: •2 of the 12 monthly SAS reconciliations were not completed by Presentation College. Cause: Lack of oversight of the monthly reconciliation control resulted in 2 months of reconciliations that were not performed and variances/discrepancies that were not investigated. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution’s records. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: Based on the announced College closure, we recommend the College complete one final reconciliation to COD for fiscal year 2023. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans 2022-2023 Award Year Cash Management – Reconciliations (Direct Loan) Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of Direct loans. Presentation College is required to reconcile the monthly School Account Statement (SAS) data file to the institution’s financial records. Condition: When testing cash management related to reconciliations, we noted the following: •2 of the 12 monthly SAS reconciliations were not completed by Presentation College. Cause: Lack of oversight of the monthly reconciliation control resulted in 2 months of reconciliations that were not performed and variances/discrepancies that were not investigated. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution’s records. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: Based on the announced College closure, we recommend the College complete one final reconciliation to COD for fiscal year 2023. Views of Responsible Officials: Management agrees with the finding.
Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the 12 monthly SAS reconciliations were not completed. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The Student Financial Aid Director completed a final reconciliation after final disbursements were made to students to ensure all aid awards was correctly reflected. Anticipated Completion Date: September 30, 2023
2022-004
During testing of enrollment reporting, the following deficiencies were noted: •7 of 19 students were not reported to NSDLS with changes in effective dates and enrollment statuses,and the certification dates were not within 60 days of the changes. •8 of 19 students were reported to NSLDS with incorrect program begin dates. Cause: Regarding other reporting issues, errors in information were caused by entry errors by the various departments using incorrect dates or programs. That information is then used to report to NSLDS; therefore, information was reported incorrectly. Regarding the incorrect effective dates and statuses, the College only reporting a portion of students with May graduation dates to NSLDS. Subsequent to the error being noted, the College has completed the full reporting for May graduates. Effect: The errors result in information being reported incorrectly. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 19 students out of 63 students with a change in status were selected for testing of enrollment reporting requirement. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a final review of status changes for fiscal year 2023 be completed so ensure all changes were properly reported to NSLDS prior to the College closure. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program 2022-2023 Award Year Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for Presentation College’s participation in the Direct loan program with regard to enrollment reporting requirements. Condition: During testing of enrollment reporting, the following deficiencies were noted: •7 of 19 students were not reported to NSDLS with changes in effective dates and enrollment statuses,and the certification dates were not within 60 days of the changes. •8 of 19 students were reported to NSLDS with incorrect program begin dates. Cause: Regarding other reporting issues, errors in information were caused by entry errors by the various departments using incorrect dates or programs. That information is then used to report to NSLDS; therefore, information was reported incorrectly. Regarding the incorrect effective dates and statuses, the College only reporting a portion of students with May graduation dates to NSLDS. Subsequent to the error being noted, the College has completed the full reporting for May graduates. Effect: The errors result in information being reported incorrectly. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 19 students out of 63 students with a change in status were selected for testing of enrollment reporting requirement. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a final review of status changes for fiscal year 2023 be completed so ensure all changes were properly reported to NSLDS prior to the College closure. Views of Responsible Officials: Management agrees with the finding.
Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, it was noted that 7 of 19 students tested were not reported to NSDLS with changes in effective dates and enrollment statuses; and the certification dates were not within 60 days of the changes and 8 of 19 students tested were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The errors noted in tested were corrected when we were notified of the errors and additional review was taken to ensure that a final enrollment roster was submitted as required as part of the close audit process. Anticipated Completion Date: September 30, 2023
In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP. Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported. Questioned Costs: None. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year(s): No. Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program 2022-2023 Award Year Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Significant Deficiency in Internal Controls over Compliance Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19 and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection. Condition: In testing key line items as indicated in the compliance supplement, we noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and, therefore, there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP. Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported. Questioned Costs: None. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year(s): No. Recommendation: We recommend all backup documentation be maintained for numbers reported on all FISAP reports and to work with the Department of Education prior to College closure to make any changes DOE will require to be made to the reports. Views of Responsible Officials: Management agrees with the finding.
Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: In testing key line items as indicated in the compliance supplement, the auditors noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: Any errors that were required to be corrected were made for 2022 and resubmitted to the Department of Education prior to the 2023 report being completed. Anticipated Completion Date: September 30, 2023
Presentation College did not maintain all records as required under the program and, as a result, subsequent to year-end, the College was required to buy back specific Perkins Loans that did not have proper documentation maintained. Cause: The College has seen significant turnover in the financial aid director role for many years and not all documentation was maintained with that turnover. Effect: The College was required to buy back a portion of the Perkins Loans. Questioned Costs: None Context/Sampling: Sampling was not used. Repeat Finding from Prior Year(s): No Recommendation: Based on the College closure, the College has liquated the Federal Perkins Loan Program and no further corrective action is needed with this finding. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Unknown Award Year Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention – Significant Deficiency in Internal Controls over Compliance Criteria: As required by the Department of Education, institutions are required to maintain original proper records for various required timeframes after loans or paid off, forgiven or cancelled. Condition: Presentation College did not maintain all records as required under the program and, as a result, subsequent to year-end, the College was required to buy back specific Perkins Loans that did not have proper documentation maintained. Cause: The College has seen significant turnover in the financial aid director role for many years and not all documentation was maintained with that turnover. Effect: The College was required to buy back a portion of the Perkins Loans. Questioned Costs: None Context/Sampling: Sampling was not used. Repeat Finding from Prior Year(s): No Recommendation: Based on the College closure, the College has liquated the Federal Perkins Loan Program and no further corrective action is needed with this finding. Views of Responsible Officials: Management agrees with the finding.
Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the program and as a result, subsequent to yearend, were required to buy back specific Perkins Loans that did not have proper documentation maintained. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: All loan documentation was provided to Department of Education as part of the liquidation process and any loans that did not have proper documentation were purchased back by the College in September 2023 and the Perkins Liquidation was complete with final reporting requirements completed. Anticipated Completion Date: September 30, 2023
FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.
During testing over the eligibility requirements, the following deficiencies were noted: ?2 of 60 students were not awarded the correct amount of Pell. Both students were under awarded for the Summer 2022 semester. ?6 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being packaged as the wrong year in school; 1 student was not given full amount of loan agreed to on packaging; and 1 student was over awarded subsidized loans as the student did not have financial need. ?4 of 60 students were not awarded the correct amount of unsubsidized loans. 3 of the students were under awarded unsubsidized loans based on being packaged as the wrong year in school. 1 student was awarded an unsubsidized loan which was not credited to student account but was reported in the COD system. ?1 of 60 students received subsidized/unsubsidized loans exceeding the aggregate limit. Student was over awarded subsidized loans in the 2021 fiscal year, and this was not properly corrected before 2022 aid was reported. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of packaging the student aid throughout the year. Effect: Students were not awarded the proper amount of aid. Questioned Costs: Pell error: $1,769 under awarded; Direct subsidized Loans: $3,485 under awarded and $3,464 over awarded; Direct unsubsidized Loans: $5,939 under awarded. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $151,658 and Direct loans of $349,576. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that new staff attend training on awarding financial to gain an understanding of the process to package the aid correctly. We also recommend that a sample number of students be reviewed by someone outside of the person completing the packaging to ensure that errors are not occurring. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-002 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.038 ? Federal Perkins Loan Program CFDA # 84.063 ? Federal Pell Grant Program 2021-2022 Award Year Eligibility ? Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Material Weakness in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program. Condition: During testing over the eligibility requirements, the following deficiencies were noted: ?2 of 60 students were not awarded the correct amount of Pell. Both students were under awarded for the Summer 2022 semester. ?6 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being packaged as the wrong year in school; 1 student was not given full amount of loan agreed to on packaging; and 1 student was over awarded subsidized loans as the student did not have financial need. ?4 of 60 students were not awarded the correct amount of unsubsidized loans. 3 of the students were under awarded unsubsidized loans based on being packaged as the wrong year in school. 1 student was awarded an unsubsidized loan which was not credited to student account but was reported in the COD system. ?1 of 60 students received subsidized/unsubsidized loans exceeding the aggregate limit. Student was over awarded subsidized loans in the 2021 fiscal year, and this was not properly corrected before 2022 aid was reported. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid department and errors occurred as part of packaging the student aid throughout the year. Effect: Students were not awarded the proper amount of aid. Questioned Costs: Pell error: $1,769 under awarded; Direct subsidized Loans: $3,485 under awarded and $3,464 over awarded; Direct unsubsidized Loans: $5,939 under awarded. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. The total aid tested in sample was Pell grants of $151,658 and Direct loans of $349,576. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that new staff attend training on awarding financial to gain an understanding of the process to package the aid correctly. We also recommend that a sample number of students be reviewed by someone outside of the person completing the packaging to ensure that errors are not occurring. Views of Responsible Officials: Management agrees with the finding.
Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: ? 2 of 60 students were not awarded the correct amount of Pell. Both students were under awarded for the Summer 2022 semester. ? 6 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being packaged as the wrong year in school; 1 student was not given full amount of loan agreed to on packaging; and 1 student was over awarded subsidized loans as the student did not have financial need. ? 4 of 60 students were not awarded the correct amount of unsubsidized loans. 3 of the students were under awarded unsubsidized loans based on being packaged as the wrong year in school. 1 student was awarded an unsubsidized loan which was not credited to student account but was reported in the COD system. ? 1 of 60 students received subsidized/unsubsidized loans exceeding the aggregate limit. Student was over awarded subsidized loans in the 2021 fiscal year, and this was not properly corrected before 2022 aid was reported. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: As described in management?s response to the prior finding, transition in the Financial Aid Office, combined with insufficient training for new staff and adequate support from external resources, contributed to a high error rate in calculation of the proper amount of aid for Pell, unsubsidized loans and subsidized loans. In response, management has redoubled efforts to improve the review of award calculations and intends to engage external resources to review award calculations for FY23. Anticipated Completion Date: The Financial Aid Office has made necessary corrections in all student accounts. Further, the Office has emphasized correct calculations of awards for both the Fall and Spring 2023 semester. Training has improved during the current fiscal year. External resources will be engaged within the next several weeks to further review the award process; proper calculation of drawdown and return of Title IV funds, and proper conduct of internal control processes including adequate monthly reconciliations of student accounts and Title IV drawdowns.
2021-004
During testing over return of Title IV funds, the following deficiencies were noted: ?5 of 8 students? percentage completion rate were calculated incorrectly which resulted in 3 of the 8students not having the correct amount of Title IV funds to be returned. ?1 of 8 students did not return Title IV funds in the required time frame. Cause: The errors all related to students who withdrew in the fall semester as the financial aid staff excluded days from institutionally scheduled breaks of at least 5 days that should not have been excluded; and, therefore, the total number of calendar days in the payment period or enrollment period was understated for purposes of the calculation of percentage of completion. The late reporting was a result of a student being missed in a batch reporting in the system. Effect: The effect of these errors resulted in aid not being returned in the proper timeframe and incorrect amounts of aid returned. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 students out of 28 were selected for testing the return of Title IV funds. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that the formula used to complete the calculation be reviewed at the start of each semester to ensure that the calculation is completed correctly. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-003 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program 2021-2022 Award Year Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned, Timely Return of Funds Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 668.22 provides the criteria and guidance on the total number of calendar days in a payment period or period of enrollment for purposes of calculating the percentage of federal aid earned. Condition: During testing over return of Title IV funds, the following deficiencies were noted: ?5 of 8 students? percentage completion rate were calculated incorrectly which resulted in 3 of the 8students not having the correct amount of Title IV funds to be returned. ?1 of 8 students did not return Title IV funds in the required time frame. Cause: The errors all related to students who withdrew in the fall semester as the financial aid staff excluded days from institutionally scheduled breaks of at least 5 days that should not have been excluded; and, therefore, the total number of calendar days in the payment period or enrollment period was understated for purposes of the calculation of percentage of completion. The late reporting was a result of a student being missed in a batch reporting in the system. Effect: The effect of these errors resulted in aid not being returned in the proper timeframe and incorrect amounts of aid returned. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 students out of 28 were selected for testing the return of Title IV funds. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that the formula used to complete the calculation be reviewed at the start of each semester to ensure that the calculation is completed correctly. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-003 Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned, Timely Return of Funds Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing over return of Title IV funds, the following deficiencies were noted: ? 5 of 8 students? percentage completion rate were calculated incorrectly which resulted in 3 of the 8 students not having the correct amount of Title IV funds to be returned. ? 1 of 8 students did not return Title IV funds in the required time frame. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: The Business Office and Financial Aid Office have examined the internal control processes to address shortcomings that have contributed to deficiencies in the calculation and return of Title IV funds. External review of internal controls during the Spring term may contribute to further corrective actions. All required corrections in student accounts noted in the findings have been made. Anticipated Completion Date: Review and corrective action ongoing.
2021-002
When testing special tests and provisions related to COD, we noted the following: ?9 of the 12 monthly SAS reconciliations were not completed by Presentation College. ?1 of 60 students was incorrectly reported to COD as having received Title IV funds. Cause: Lack of oversight over the monthly reconciliation control resulted in 9 months of reconciliations that were not performed by Presentation College and variances/discrepancies that were not investigated. For the 1 student error, a batch process pushed the loan disbursement to COD, but the student did not receive the loan disbursement in the student account, so funds were never disbursed to student. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Lack of reconciliations did result in an error of a student not receiving a loan that was reported to COD. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward and a review process be in place to ensure the reconciliations are completed by someone outside of the person preparing the reconciliation. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-004 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2021-2022 Award Year Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of direct loans. Presentation College is required to reconcile the monthly School Account Statement (SAS) data file to the institution?s financial records. Condition: When testing special tests and provisions related to COD, we noted the following: ?9 of the 12 monthly SAS reconciliations were not completed by Presentation College. ?1 of 60 students was incorrectly reported to COD as having received Title IV funds. Cause: Lack of oversight over the monthly reconciliation control resulted in 9 months of reconciliations that were not performed by Presentation College and variances/discrepancies that were not investigated. For the 1 student error, a batch process pushed the loan disbursement to COD, but the student did not receive the loan disbursement in the student account, so funds were never disbursed to student. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Lack of reconciliations did result in an error of a student not receiving a loan that was reported to COD. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward and a review process be in place to ensure the reconciliations are completed by someone outside of the person preparing the reconciliation. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-004 Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans Finding Summary: When testing special tests and provisions related to COD, the following was noted: ? 9 of the 12 monthly SAS reconciliations were not completed by Presentation College. ? 1 of 60 students was incorrectly reported to COD as having received Title IV funds. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has identified an outside consultant with the appropriate expertise to review current monthly SAS reconciliation processes. Anticipated Completion Date: We anticipate this external review to be completed over the next several weeks with implementation of recommended changes made prior to the end of the Spring term.
2021-003
During testing of enrollment reporting, the following deficiencies were noted: ?1 of 81 students was reported to NSDLS with incorrect effective dates. ?3 of 81 students were reported to NSLDS with incorrect status changes. ?9 of 81 students were reported to NSLDS with incorrect program begin dates. Cause: For other reporting issues, errors in information were caused by entry errors by the various departments for incorrect dates or programs. That information is then used to report to NSLDS, so information was reported incorrectly. Effect: The errors result in information being reported incorrectly. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students out of 393 students with a change in status were selected for testing of enrollment reporting requirement. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the financial aid and registrar?s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information is accurately reported. We also recommend that a monitoring system be put into place to track status changes and reporting of those status changes that can be monitored by financial aid or the registrar?s office. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-005 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program 2021-2022 Award Year Special Tests and Provisions ? Enrollment Reporting Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 685.309 sets forth the criteria for administrative and fiscal control and fund accounting requirements for Presentation College?s participation in the Direct loan program with regard to enrollment reporting requirements. Condition: During testing of enrollment reporting, the following deficiencies were noted: ?1 of 81 students was reported to NSDLS with incorrect effective dates. ?3 of 81 students were reported to NSLDS with incorrect status changes. ?9 of 81 students were reported to NSLDS with incorrect program begin dates. Cause: For other reporting issues, errors in information were caused by entry errors by the various departments for incorrect dates or programs. That information is then used to report to NSLDS, so information was reported incorrectly. Effect: The errors result in information being reported incorrectly. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students out of 393 students with a change in status were selected for testing of enrollment reporting requirement. Repeat Finding from Prior Year(s): No. Recommendation: We recommend the financial aid and registrar?s offices review controls over information being entered into the software for dates and other academic information that is required to be reported to ensure that status changes and other academic information is accurately reported. We also recommend that a monitoring system be put into place to track status changes and reporting of those status changes that can be monitored by financial aid or the registrar?s office. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-005 Special Tests and Provisions ? Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, the following deficiencies were noted: ? 1 of 81 students was reported to NSDLS with incorrect effective dates. ? 3 of 81 students were reported to NSLDS with incorrect status changes. ? 9 of 81 students were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has noted the high error rate and taken steps to improve review of reporting student enrollment information to NSDLS. The external review planned for the Spring term will also address this high error rate. Anticipated Completion Date: Ongoing.
During 2022, out of the total of 60 students tested, 3 students were not properly reported as being required to be monitored by NSLDS. Cause: In the process of monitoring, 3 students were inadvertently missed, and it was not communicated to NSLDS to monitor those students. Effect: Students were missed in being monitored by NSLDS as required. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that at least monthly during the semester, reports are generated to ensure that all students that need to be included in transfer monitoring are added as required. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-006 Department of Education Student Financial Aid Cluster CFDA # 84.033 ? Federal Work Study Program CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program CFDA # 84.268 ? Federal Direct Student Loans 2021-2022 Award Year Special Tests and Provisions: Disbursements to or on Behalf of Students ? Lack of Transfer Monitoring Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR 668.19 sets forth the criteria which requires Presentation College to inform NSLDS about transfer students in order for NSLDS to monitor those students and alert Presentation College of any relevant financial aid history changes. Condition: During 2022, out of the total of 60 students tested, 3 students were not properly reported as being required to be monitored by NSLDS. Cause: In the process of monitoring, 3 students were inadvertently missed, and it was not communicated to NSLDS to monitor those students. Effect: Students were missed in being monitored by NSLDS as required. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that at least monthly during the semester, reports are generated to ensure that all students that need to be included in transfer monitoring are added as required. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-006 Special Tests and Provisions ? Lack of Transfer Monitoring Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 ? Federal Work Study Program CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During 2022, out of the total of 60 students tested, 3 students were not properly reported as being required to be monitored by NSLDS. Responsible Individuals: Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has noted the error rate and taken steps to improve review of reporting student enrollment information to NSDLS. The external review planned for the Spring term will also address this error rate. Anticipated Completion Date: Ongoing.
2021-001
During 2022, out of the total of 60 students tested, 9 students did not receive proper notification of the loan disbursement required under the CFR. Cause: For the disbursements that occurred on October 26, 2021, and November 8, 2021, notifications were not made to students receiving aid on those dates. Effect: Students and/or parents were not made aware of the disbursement being received and so did not receive the communication required under CFR. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend additional tracking and monitoring of the disbursement dates to ensure that required communication is completed for all disbursements date. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-007 Department of Education Student Financial Aid Cluster CFDA # 84.033 ? Federal Work Study Program CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program CFDA # 84.268 ? Federal Direct Student Loans 2021-2022 Award Year Special Tests and Provisions: Disbursements to or on Behalf of Students ? Lack of Documentation for Disbursement Notices. Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR 668.165 sets forth the criteria which requires Presentation College to send notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account with a Direct loan. Condition: During 2022, out of the total of 60 students tested, 9 students did not receive proper notification of the loan disbursement required under the CFR. Cause: For the disbursements that occurred on October 26, 2021, and November 8, 2021, notifications were not made to students receiving aid on those dates. Effect: Students and/or parents were not made aware of the disbursement being received and so did not receive the communication required under CFR. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 485 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend additional tracking and monitoring of the disbursement dates to ensure that required communication is completed for all disbursements date. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-007 Special Tests and Provisions ? Disbursements to or on Behalf of Students ? Lack of Documentation for Disbursement Notices. Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 ? Federal Work Study Program CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During 2022, out of the total of 60 students tested, 9 students did not receive proper notification of the loan disbursement required under the CFR. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: Management has initiated a review of its student notification process for loan disbursement. Corrective actions are planned for the Spring term. Anticipated Completion Date: Ongoing.
During testing of allowable costs/activities of the HEERF Student portion, the following errors were noted: ?1 of 60 students was not directly issued their HEERF disbursement. ?1 of 60 students did not have a documented consent form prior to applying the grant against thestudent?s account. ?6 of 60 students did not have documentation to support the criteria used to prioritize exceptional needas set forth by Presentation College. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid and accounting departments and errors occurred or documentation was misplaced for awarding aid to students. Effect: Aid could have been awarded to students that was not properly awarded based on the criteria set forth by Presentation College. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students out of 598 who received HEERF Student portion throughout the year were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that documentation be maintained as required by the grant agreement to support the decision to provide aid to students. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-008 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) CFDA # 84.425E ? HEERF Student Award Numbers P425E201987-20A and P425E201987-20B Allowable Costs/Activities ? Student Significant Deficiency in Internal Controls over Compliance and noncompliance Criteria: CRRSSA section 314(c)(3) sets forth the criteria for allowable costs/activities in regard to student aid and grants to students. Additional guidance is also available in Department of Education FAQs that are available on the Department of Education website. Condition: During testing of allowable costs/activities of the HEERF Student portion, the following errors were noted: ?1 of 60 students was not directly issued their HEERF disbursement. ?1 of 60 students did not have a documented consent form prior to applying the grant against thestudent?s account. ?6 of 60 students did not have documentation to support the criteria used to prioritize exceptional needas set forth by Presentation College. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid and accounting departments and errors occurred or documentation was misplaced for awarding aid to students. Effect: Aid could have been awarded to students that was not properly awarded based on the criteria set forth by Presentation College. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 60 students out of 598 who received HEERF Student portion throughout the year were selected for testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that documentation be maintained as required by the grant agreement to support the decision to provide aid to students. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-008 Allowable Costs/Activities ? Student Federal Agency Name: Department of Education Program Name: Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) CFDA # 84.425E ? HEERF Student Finding Summary: During testing of allowable costs/activities of the HEERF Student portion, the following errors were noted: ? 1 of 60 students was not directly issued their HEERF disbursement. ? 1 of 60 students did not have a documented consent form prior to applying the grant against the student?s account. ? 6 of 60 students did not have documentation to support the criteria used to prioritize exceptional need as set forth by Presentation College. Responsible Individuals: Jessica Papa, Director of Financial Aid Corrective Action Plan: Management agrees with this finding and we are reviewing internal processes to address the disbursement and documentation shortcomings identified. Anticipated Completion Date: Ongoing.
During testing of allowable costs/activities of HEERF Institutional portion, it was noted that 20 students who were to have student debt and unpaid balances discharged, did not have the proper amount discharged from accounts. In testing, it was noted that Presentation College requested the funds be drawn from G5 in January 2022 when student accounts with debt to be discharged were determined. Student accounts were not credited until April 2022 which resulted in differences between expected amounts to be forgiven and actual amounts that were forgiven. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid and accounting departments during the year. It was believed the student balances were discharged in January, and when the issue was noticed, the student accounts were discharged but no one noticed the variances in the amounts. Effect: Presentation College drew additional funds that were not used to discharge debt. Questioned Costs: $30,719. Context/Sampling: Total lost revenue claimed for student debt discharged was $243,810, of which 100% was tested. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a conversation with Department of Education occur to correct this error. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-009 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) CFDA # 84.425F ? HEERF Institutional Award Numbers P425F201808-20A and P425201808-20B Allowable Costs/Activities ? Institutional Significant Deficiency in Internal Controls over Compliance and noncompliance Criteria: CRRSSA section 314 (c) (1-3) and ARP section 2003, sets forth the criteria for allowable costs/activities in regard to the HEERF Institutional portion. Additional guidance is also available in Department of Education FAQs that are available on the Department of Education website. Condition: During testing of allowable costs/activities of HEERF Institutional portion, it was noted that 20 students who were to have student debt and unpaid balances discharged, did not have the proper amount discharged from accounts. In testing, it was noted that Presentation College requested the funds be drawn from G5 in January 2022 when student accounts with debt to be discharged were determined. Student accounts were not credited until April 2022 which resulted in differences between expected amounts to be forgiven and actual amounts that were forgiven. Cause: Presentation College experienced a staffing shortage along with turnover in the financial aid and accounting departments during the year. It was believed the student balances were discharged in January, and when the issue was noticed, the student accounts were discharged but no one noticed the variances in the amounts. Effect: Presentation College drew additional funds that were not used to discharge debt. Questioned Costs: $30,719. Context/Sampling: Total lost revenue claimed for student debt discharged was $243,810, of which 100% was tested. Repeat Finding from Prior Year(s): No. Recommendation: We recommend a conversation with Department of Education occur to correct this error. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-009 Allowable Costs/Activities ? Institutional Federal Agency Name: Department of Education Program Name: Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) CFDA # 84.425F ? HEERF Institutional Finding Summary: During testing of allowable costs/activities of HEERF Institutional portion, it was noted that 20 students who were to have student debt and unpaid balances discharged, did not have the proper amount discharged from accounts. In testing, it was noted that Presentation College requested the funds be drawn from G5 in January 2022 when student accounts with debt to be discharged were determined. Student accounts were not credited until April 2022 which resulted in differences between expected amounts to be forgiven and actual amounts that were forgiven. Responsible Individuals: James (Rocky) Query, Interim CFO Corrective Action Plan: The Business Office has reviewed the timing of G5 draws and posting to student accounts to address this finding. Review of this finding with the external expert review planned for this Spring may also contribute to further changes in internal control processes. Anticipated Completion Date: Ongoing.
During testing of reporting, the following deficiencies were noted: ?The student aid report for the quarter ending December 31, 2021, misreported the cumulative totalawarded to students. ?The student aid reports for the quarters ending September 30, 2021, and December 31, 2021, were notuploaded to the Presentation College website within 10 days of quarter-end. ?The institutional aid report for the quarter ending September 30, 2021, was not uploaded to thePresentation College website within 10 days of quarter-end. ?The annual report for 2021 was submitted on July 29, 2022, which was after the required reporting dateof May 6, 2022. Cause: The errors were caused by a lack of understanding of the reporting requirements. Effect: The reporting packets were not available on the website within the required timeframe and the annual report was submitted late to the Department of Education. Questioned Costs: None. Context/Sampling: All quarterly and annual reports that were required to be completed were tested. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that a tracking schedule is made by Presentation College which is monitored to ensure the requirements for reporting are met in the timeframe allowed under the grant agreements. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2022-010 Department of Education Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) CFDA # 84.425E ? HEERF Student Award Numbers P425E201987-20A and P425E201987-20B CFDA # 84.425F ? HEERF Institutional Award Numbers P425F201808-20A and P425201808-20B Reporting Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: CRRSSA section 314 (e) and CARES Act 18004 (e), sets forth the criteria for reporting requirements. Condition: During testing of reporting, the following deficiencies were noted: ?The student aid report for the quarter ending December 31, 2021, misreported the cumulative totalawarded to students. ?The student aid reports for the quarters ending September 30, 2021, and December 31, 2021, were notuploaded to the Presentation College website within 10 days of quarter-end. ?The institutional aid report for the quarter ending September 30, 2021, was not uploaded to thePresentation College website within 10 days of quarter-end. ?The annual report for 2021 was submitted on July 29, 2022, which was after the required reporting dateof May 6, 2022. Cause: The errors were caused by a lack of understanding of the reporting requirements. Effect: The reporting packets were not available on the website within the required timeframe and the annual report was submitted late to the Department of Education. Questioned Costs: None. Context/Sampling: All quarterly and annual reports that were required to be completed were tested. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that a tracking schedule is made by Presentation College which is monitored to ensure the requirements for reporting are met in the timeframe allowed under the grant agreements. Views of Responsible Officials: Management agrees with the finding.
Finding 2022-010 Reporting Federal Agency Name: Department of Education Program Name: Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF) CFDA # 84.425E ? HEERF Student CFDA # 84.425F ? HEERF Institutional Finding Summary: During testing of reporting, the following deficiencies were noted: ? The student aid report for the quarter ending December 31, 2021, misreported the cumulative total awarded to students. ? The student aid reports for the quarters ending September 30, 2021, and December 31, 2021, were not uploaded to the Presentation College website within 10 days of quarter-end. ? The institutional aid report for the quarter ending September 30, 2021, was not uploaded to the Presentation College website within 10 days of quarter-end. ? The annual report for 2021 was submitted on July 29, 2022 which was after the required reporting date of May 6, 2022. Responsible Individuals: James (Rocky) Query, Interim CFO and Jessica Papa, Director of Financial Aid Corrective Action Plan: The Business Office and Financial Aid Office have initiated a review of these reporting deficiencies with corrective action to be taken as soon as possible. Anticipated Completion Date: Ongoing with completion anticipated prior to March 30th.
FAC accepted this audit on November 28, 2021 — management decision was due May 28, 2022.
During 2021, out of the total of 60 students tested, 9 students were not properly reported as being required to be monitored by NSLDS. Cause: During fall 2020, the financial aid director ran the reports for students that required monitoring at the beginning of the semester. In doing this, students that transferred into the college after the date the report was run were missed in the monitoring process. Effect: Students were missed in being monitored as required. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 520 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that at least monthly during the semester, reports are generated to ensure that all students that need to be included in transfer monitoring are added as required. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2021-001 Department of Education Student Financial Aid Cluster CFDA # 84.033 ? Federal Workstudy Program CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.038 ? Federal Perkins Loan Program CFDA # 84.063 ? Federal Pell Grant Program 2020-2021 Award Year Eligibility ? Lack of Transfer Monitoring Significant Deficiency in Internal Controls over Compliance Criteria: 34 CRF 668.19 set criteria which requires the College to inform NSLDA about transfer students in order for NSLDS to monitor those students and alert the college for any relevant financial aid history changes. Condition: During 2021, out of the total of 60 students tested, 9 students were not properly reported as being required to be monitored by NSLDS. Cause: During fall 2020, the financial aid director ran the reports for students that required monitoring at the beginning of the semester. In doing this, students that transferred into the college after the date the report was run were missed in the monitoring process. Effect: Students were missed in being monitored as required. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students who received Title IV disbursements out of 520 students who received aid. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that at least monthly during the semester, reports are generated to ensure that all students that need to be included in transfer monitoring are added as required. Views of Responsible Officials: Management agrees with the finding.
Finding 2021-001 Eligibility ? Lack of Transfer Monitoring Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 ? Federal Workstudy Program CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.038 ? Federal Perkins Loan Program CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: During 2021, out of the total of 60 students tested, 9 students were not properly reported as being required to be monitored by NSLDS. Responsible Individuals: Amber Brockel, Director of Financial Aid Corrective Action Plan: Each semester, the Office of Financial Aid will run the transfer monitoring report on a monthly basis for the first 3 months of the semester to determine students that require transfer and to ensure all students are flagged that require monitoring. Anticipated Completion Date: November 30, 2021
Three out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had an incorrect calculation of the percentage of completion for calculating the amount of federal aid earned. The College determined and corrected the error, but amounts were not remitted back to the Department of Education within the required timeframe. Cause: The errors all related to students who withdrew in the fall semester as the financial aid staff excluded days from institutionally scheduled breaks of at least 5 days that should not have been excluded; and, therefore, the total number of calendar days in the payment period or enrollment period was understated for purposes of the calculation of percentage of completion. Effect: The effect of these errors resulted in aid not being returned in the proper timeframe. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 students out of 22 were selected for testing the Return of Title IV Funds. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that the formula used to complete the calculation be reviewed at the start of each semester to ensure that the calculation is completed correctly. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2021-002 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program 2020-2021 Award Year Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 668.22 provides the criteria and guidance on the total number of calendar days in a payment period or period of enrollment for purposes of calculating the percentage of federal aid earned. Condition: Three out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had an incorrect calculation of the percentage of completion for calculating the amount of federal aid earned. The College determined and corrected the error, but amounts were not remitted back to the Department of Education within the required timeframe. Cause: The errors all related to students who withdrew in the fall semester as the financial aid staff excluded days from institutionally scheduled breaks of at least 5 days that should not have been excluded; and, therefore, the total number of calendar days in the payment period or enrollment period was understated for purposes of the calculation of percentage of completion. Effect: The effect of these errors resulted in aid not being returned in the proper timeframe. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 students out of 22 were selected for testing the Return of Title IV Funds. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that the formula used to complete the calculation be reviewed at the start of each semester to ensure that the calculation is completed correctly. Views of Responsible Officials: Management agrees with the finding.
Finding 2021-002 Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: Three out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had an incorrect calculation of the percentage of completion for calculating the amount of federal aid earned. The College determined and corrected the error, but amounts were not remitted back to the Department of Education within the required timeframe. Responsible Individuals: Amber Brockel, Director of Financial Aid Ben Allen, Financial Aid Counselor Corrective Action Plan: The R2T4 calculator was not set up to properly and reflected a break of 5 days or more that did not occur in the fall semester, resulting in incorrect R2T4 calculations. The form was reviewed subsequent to the initial calculations for student and the error was discovered but the return of federal money was outside the allowed timeframe. The Director of Financial Aid will do a secondary check of the R2T4 calculator set up in the COD system each semester to ensure the calculation is set up completely. The Office of Financial Aid has made the necessary corrections to the students impacted by the incorrect calculations as soon as error was noted so no further corrections were needed. Anticipated Completion Date: November 2021
2020-003
Five of the 12 monthly SAS reconciliations were not completed by the College. Cause: Lack of oversight over the monthly reconciliation control resulted in five months of reconciliations that were not performed by the College. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2021-003 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2020-2021 Award Year Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of direct loans. The College is required to reconcile the monthly School Account Statement (SAS) data file to the institution?s financial records. Condition: Five of the 12 monthly SAS reconciliations were not completed by the College. Cause: Lack of oversight over the monthly reconciliation control resulted in five months of reconciliations that were not performed by the College. Effect: The lack of monthly reconciliations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconciliations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward. Views of Responsible Officials: Management agrees with the finding.
Finding 2021-003 Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans Finding Summary: A monthly reconciliation of the School Account Statement (SAS) data file to the institution?s financial records was not performed for 5 out of 12 months during the award year. Responsible Individuals: Amber Brockel, Director of Financial Aid Ben Allen, Financial Aid Counselor Corrective Action Plan: Federal loan reconciliation was not performed on a monthly basis as required by the Department of Education. The Director of Financial Aid has added this task to the office?s Outlook task calendar as a reminder to complete reconciliation each month. The Office of Financial Aid will ensure that loan reconciliation files are imported and loan reconciliation is completed on a monthly basis as required by the Department of Education. Anticipated Completion Date: November 2021
2020-004
One out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of Pell Grant. Two out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of subsidized federal direct student loans. Cause: The errors in Pell Grant awards was caused by an error in calculation of Pell Grant that was available to the student for a summer session. The error in Direct Loan awards were caused by award packaging errors in which the student was awarded subsidized loans when they were not eligible for those loans based than their calculated financial need. The students would have been eligible for unsubsidized loans so total aid was not overawarded. Effect: These errors can lead to an incorrect amount of aid awarded to the students. Questioned Costs: Underpayment of Pell grant of $425 with a total Pell tested in sample of $100,439. Overpayment of subsidized loans of $7,336 with a total subsidized loans in sample of $181,542. Context/Sampling: A nonstatistical sample of 60 students out of 520 who received federal aid throughout the year were selected for eligibility testing. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that financial aid staff review and improve controls in the packaging and calculating of federal awards to ensure greater accuracy of the award amount. In addition, we recommend correcting the errors in incorrect aid given out in error or giving the student aid who was under awarded. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴2021-004 Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program 2020-2021 Award Year Eligibility ? Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program. Condition: One out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of Pell Grant. Two out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of subsidized federal direct student loans. Cause: The errors in Pell Grant awards was caused by an error in calculation of Pell Grant that was available to the student for a summer session. The error in Direct Loan awards were caused by award packaging errors in which the student was awarded subsidized loans when they were not eligible for those loans based than their calculated financial need. The students would have been eligible for unsubsidized loans so total aid was not overawarded. Effect: These errors can lead to an incorrect amount of aid awarded to the students. Questioned Costs: Underpayment of Pell grant of $425 with a total Pell tested in sample of $100,439. Overpayment of subsidized loans of $7,336 with a total subsidized loans in sample of $181,542. Context/Sampling: A nonstatistical sample of 60 students out of 520 who received federal aid throughout the year were selected for eligibility testing. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that financial aid staff review and improve controls in the packaging and calculating of federal awards to ensure greater accuracy of the award amount. In addition, we recommend correcting the errors in incorrect aid given out in error or giving the student aid who was under awarded. Views of Responsible Officials: Management agrees with the finding.
Finding 2021-004 Eligibility ? Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: One out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of Pell Grant. Two out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of subsidized federal direct student loans. Responsible Individuals: Amber Brockel, Director of Financial Aid Corrective Action Plan: The Director of Financial Aid will work with a consultant from 3D Technologies to create a report that identifies students who are incorrectly awarded federal aid. The Office of Financial Aid can run that report on a weekly basis to ensure that all students are being awarded correctly and/or to make any necessary corrections to aid packages. Anticipated Completion Date: January 2022
2020-001
FAC accepted this audit on December 6, 2020 — management decision was due June 6, 2021.
Three out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of Pell Grant. Four out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of federal direct student loans. Three of the four incorrect direct loan awards resulted in an incorrect award of subsidized loans and one resulted in an incorrect award of an unsubsidized loan. Cause: The errors in Pell Grant awards were caused by award packaging errors in the use of an incorrect ISIR and EFC used, or use of an incorrect student enrollment status in calculating the award. The errors in Direct Loan awards were caused by award packaging errors in which the incorrect year of study was used, the calculated award amount exceeded a student?s aggregate loan limit, or the student was awarded more than their calculated financial need. Effect: These errors can lead to an incorrect amount of aid awarded to the students. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 students out of 523 who received federal aid throughout the year were selected for eligibility testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that financial aid staff review and improve controls in the packaging and calculating of federal awards to ensure greater accuracy of the award amount. In addition, we recommend returning overawards to the Department of Education and disbursing additional aid to those students who were noted as being underawarded. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.063 ? Federal Pell Grant Program CFDA # 84.268 ? Federal Direct Student Loans 2019-2020 Award Year Eligibility ? Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Material Weakness in Internal Controls over Compliance Criteria: 34 CFR section 690 provides the applicable criteria and guidance on awards under the Federal Pell Grant Program. 34 CFR section 685 provides the applicable criteria and guidance on awards under the Federal Direct Student Loans Program. Condition: Three out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of Pell Grant. Four out of the 60 students tested who had federal aid disbursed to them during the year were awarded an incorrect amount of federal direct student loans. Three of the four incorrect direct loan awards resulted in an incorrect award of subsidized loans and one resulted in an incorrect award of an unsubsidized loan. Cause: The errors in Pell Grant awards were caused by award packaging errors in the use of an incorrect ISIR and EFC used, or use of an incorrect student enrollment status in calculating the award. The errors in Direct Loan awards were caused by award packaging errors in which the incorrect year of study was used, the calculated award amount exceeded a student?s aggregate loan limit, or the student was awarded more than their calculated financial need. Effect: These errors can lead to an incorrect amount of aid awarded to the students. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 students out of 523 who received federal aid throughout the year were selected for eligibility testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that financial aid staff review and improve controls in the packaging and calculating of federal awards to ensure greater accuracy of the award amount. In addition, we recommend returning overawards to the Department of Education and disbursing additional aid to those students who were noted as being underawarded. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.063 ? Federal Pell Grant Program CFDA # 84.268 ? Federal Direct Student Loans Finding Summary: Three out of 60 students tested were awarded an incorrect amount of Pell Grant. Four out of 60 students tested were awarded an incorrect amount of federal direct loans. Responsible Individuals: Amber Brockel, Director of Financial Aid Ben Allen, Financial Aid Counselor Corrective Action Plan: The students identified during testing were disbursed incorrect federal aid amounts. Two of the students who were incorrectly disbursed Pell Grant funds were awarded using incorrect ISIR transactions. The third student?s enrollment did not match the Pell Grant amount disbursed. Four students were identified as being overpaid in the federal loan programs. The Office of Financial Aid has made the necessary corrections to these students? accounts and has adjusted the amount of federal financial aid funds through the Department of Education. We have created a report with our consultant from 3D Technology to catch potential federal loan over awards and will also be utilizing an excel spreadsheet similar to what is used during audit to find any potential Pell Grant over awards. Anticipated Completion Date: December 1, 2020 April 15, 2021-ongoing process
In testing key line items as indicated in the compliance supplement, we noted 28 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and therefore there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP. Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that financial aid staff take greater care in compiling the FISAP and ensure that all supporting documentation used in preparation of the report is retained. Additionally, we recommend the College reassess existing controls and procedures over the review of the FISAP prior to submission. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.033 ? Federal Workstudy Program CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.038 ? Federal Perkins Loan Program 2019-2020 Award Year Reporting ? Special Reporting ? Fiscal Operations Report and Application to Participate (FISAP) Significant Deficiency in Internal Controls over Compliance Criteria: OMB No. 1845-0030 is the valid OMB control number for the FISAP and responding to this collection is mandatory in accordance with 34 CFR 674.19, 34 CFR 675.19, and 34 CFR 676.19. The FISAP report itself identifies the relevant criteria and information requested in this information collection. Condition: In testing key line items as indicated in the compliance supplement, we noted 28 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Cause: Proper supporting documentation used in preparing the FISAP report was not retained by College personnel and therefore there was either no support to provide for testing or re-created support did not agree to amounts originally reported in the FISAP. Effect: Lack of supporting documentation for amounts reported in the FISAP or supporting documentation that does not agree to amounts reported can lead to incorrect information being reported or bring into question accuracy of amounts reported. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that financial aid staff take greater care in compiling the FISAP and ensure that all supporting documentation used in preparation of the report is retained. Additionally, we recommend the College reassess existing controls and procedures over the review of the FISAP prior to submission. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 ? Federal Workstudy Program CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.038 ? Federal Perkins Loan Program Finding Summary: There were 28 key line items for which amounts reported in the FISAP did not agree to supporting documentation and records provided for testing resulting from the supporting documentation not being adequately maintained to support the amounts in the report. Responsible Individuals: Amber Brockel, Director of Financial Aid Corrective Action Plan: Line items on the FISAP did not have proper documentation saved and the information was not able to be re-created with the report used to complete the 19/20 FISAP. The Director of Financial Aid worked with a consultant from 3D Technology, the company that supports CAMS, to set up and utilize the FISAP reporting mechanism within CAMS. This reporting has been tested for accuracy and has been saved to properly and adequately document the information used to complete the FISAP report for the 20-21 year. The Office of Financial Aid is working to re-open the FISAP for the 19/20 year and make the necessary corrections to the data for which no documentation was available using the information from the FISAP report within CAMS. Anticipated Completion Date: November 20, 2020
Three out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had an incorrect calculation of the percentage of completion for calculating the amount of federal aid earned. In all three instances, the College undercalculated the amount of aid earned by the student. Cause: The errors all related to students who withdrew in the Spring semester as the financial aid staff did not exclude days from institutionally scheduled breaks of at least 5 days and therefore the total number of calendar days in the payment period or enrollment period was overstated for purposes of the calculation of percentage of completion. Effect: The effect of these errors resulted in each student?s calculation of amount of aid needing to be returned to be overstated due to the error in the percentage of completion. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 students out of 19 were selected for testing the Return of Title IV Funds. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that financial aid staff take greater care in computing the Return of Title IV calculation to ensure accuracy of the calculation and amount of aid to be returned by the student. Additionaly we recommend refunding the applicable students the amount of aid that was incorrectly calculated as needing to be returned. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program 2019-2020 Award Year Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR section 668.22 provides the criteria and guidance on the total number of calendar days in a payment period or period of enrollment for purposes of calculating the percentage of federal aid earned. Condition: Three out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had an incorrect calculation of the percentage of completion for calculating the amount of federal aid earned. In all three instances, the College undercalculated the amount of aid earned by the student. Cause: The errors all related to students who withdrew in the Spring semester as the financial aid staff did not exclude days from institutionally scheduled breaks of at least 5 days and therefore the total number of calendar days in the payment period or enrollment period was overstated for purposes of the calculation of percentage of completion. Effect: The effect of these errors resulted in each student?s calculation of amount of aid needing to be returned to be overstated due to the error in the percentage of completion. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 students out of 19 were selected for testing the Return of Title IV Funds. Repeat Finding from Prior Year(s): Yes. Recommendation: We recommend that financial aid staff take greater care in computing the Return of Title IV calculation to ensure accuracy of the calculation and amount of aid to be returned by the student. Additionaly we recommend refunding the applicable students the amount of aid that was incorrectly calculated as needing to be returned. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program Finding Summary: Three out of 8 students tested for Return of Title IV Funds had an incorrect calculation of the percentage of term completed due to the calculation not excluding institutionally scheduled breaks of at least 5 days. The result was the amount earned was undercalculated for these three students. Responsible Individuals: Amber Brockel, Director of Financial Aid Ben Allen, Financial Aid Counselor Corrective Action Plan: The R2T4 calculator was not set up to properly reflect the College?s spring break of 5 days or more, resulting in incorrect R2T4 calculations. The Director of Financial Aid will do a secondary check of the R2T4 calculator set up in the COD system each semester to ensure that all institutionally scheduled breaks of 5 days or more are accounted for. The Office of Financial Aid has made the necessary corrections to the students impacted by the incorrect calculations and adjusted their federal financial aid through the Department of Education. Anticipated Completion Date: November 6, 2020
2019-001
Ten of the 12 monthly SAS reconcilations were not completed by the College. Cause: Lack of oversight over the monthly reconciliation control resulted in 10 months of reconcilations that were not performed by the College. Effect: The lack of monthly reconcilations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconcilations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2019-2020 Award Year Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Direct Loan) Significant Deficiency in Internal Controls over Compliance Criteria: 34 CFR sections 685.301 and 685.303 provide the criteria and guidance for origination and processing of direct loans. The College is required to reconcile the monthly School Account Statement (SAS) data file to the institution?s financial records. Condition: Ten of the 12 monthly SAS reconcilations were not completed by the College. Cause: Lack of oversight over the monthly reconciliation control resulted in 10 months of reconcilations that were not performed by the College. Effect: The lack of monthly reconcilations of SAS data files can result in discrepancies not being found in a timely manner between amounts reported in COD compared to the institution?s records. Questioned Costs: None reported. Context/Sampling: All 12 monthly reconcilations were selected for testing to ascertain that a reconciliation is being performed on a monthly basis. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that controls be revised to ensure that a monthly reconciliation of the SAS data file is being performed on a monthly basis going forward. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans Finding Summary: A monthly reconciliation of the School Account Statement (SAS) data file to the institution?s financial records was not performed for 10 out of 12 months during the award year. Responsible Individuals: Amber Brockel, Director of Financial Aid Ben Allen, Financial Aid Counselor Corrective Action Plan: Federal loan reconciliation was not performed on a monthly basis as required by the Department of Education. The Director of Financial Aid has added this task to the office?s Outlook task calendar as a reminder to complete reconciliation each month. The Office of Financial Aid will ensure that loan reconciliation files are imported and loan reconciliation is completed on a monthly basis as required by the Department of Education. Anticipated Completion Date: October 10, 2020
Presentation College did not perform a formal risk assessment as required. Consequently, safeguards were not documented based on identified risks. Cause: The College?s designated individual to coordinate the information security program is aware of the requirements. However, the risk assessment was not complete as of June 30, 2020. Effect: We were unable to determine the risks identified and the related safeguard(s) for each risk identified. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: Yes, prior year finding 2019-004. Recommendation: We recommend performing a risk assessment that addresses employee training and management; information systems; and detecting, preventing, and responding to attacks as noted in 16 CFR Section 314.4. Based on the risk assessment, safeguards should be documented based on specific risks identified and clearly linked to specific risks identified. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program CFDA # 84.033 ? Federal Work-Study Program CFDA # 84.038 ? Federal Perkins Loan Program 2019-2020 Award Year Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security Material Weakness in Internal Control over Compliance Criteria: 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). 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. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition: Presentation College did not perform a formal risk assessment as required. Consequently, safeguards were not documented based on identified risks. Cause: The College?s designated individual to coordinate the information security program is aware of the requirements. However, the risk assessment was not complete as of June 30, 2020. Effect: We were unable to determine the risks identified and the related safeguard(s) for each risk identified. Questioned Costs: None reported. Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: Yes, prior year finding 2019-004. Recommendation: We recommend performing a risk assessment that addresses employee training and management; information systems; and detecting, preventing, and responding to attacks as noted in 16 CFR Section 314.4. Based on the risk assessment, safeguards should be documented based on specific risks identified and clearly linked to specific risks identified. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans CFDA # 84.007 ? Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 ? Federal Pell Grant Program CFDA # 84.033 ? Federal Work-Study Program CFDA # 84.038 ? Federal Perkins Loan Program Finding Summary: The College did not perform a formal risk assessment in accordance with the minimum requirements stated in 16 CFR Section 314.4. Responsible Individuals: Marty LeCompte, IT Manager Corrective Action Plan: The College did not perform a formal risk assessment during the 19/20 year in accordance with the GLBA. The IT Manager is developing a formal risk assessment plan to identify any potential risks or threats and how to safeguard the College against these risks. The plan will also include policy and protocol on what to do in the event of a data breach. The IT Manager is also coordinating risk assessments throughout the College to ensure that all users are educated on what constitutes a data breach and are informed of protocol in the event of a data breach. Anticipated Completion Date: December 1, 2020
2019-004
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
One out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had not received the correct reimbursement. Cause: The error was caused by a lack of oversight in the preparation of the Return of Title IV calculation and an incorrect withdrawal date used. Effect: These errors can lead to an incorrect amount of aid returned to the students. Questioned Costs: $277 Context/Sampling: A nonstatistical sample of 8 students who withdrew during the school year and had a return of Title IV funds calculation completed out of a population of 29 students were selected for testing the calculation of the return of the Title IV funds as well as the disbursement to the student. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend that financial aid staff take greater care in computing the Return of Title IV calculation to ensure accuracy of the calculation and amount of aid to be returned to the student, if any. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2018-2019 Award Year Special Tests and Provisions ? Return of Title IV Funds ? Calculation of the Amount of Title IV Assistance to be Returned Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR section 668.22(e) provides the criteria and guidance on the calculation of Title IV assistance earned by the student and calculation of the amount unearned and required to be returned. Condition: One out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had not received the correct reimbursement. Cause: The error was caused by a lack of oversight in the preparation of the Return of Title IV calculation and an incorrect withdrawal date used. Effect: These errors can lead to an incorrect amount of aid returned to the students. Questioned Costs: $277 Context/Sampling: A nonstatistical sample of 8 students who withdrew during the school year and had a return of Title IV funds calculation completed out of a population of 29 students were selected for testing the calculation of the return of the Title IV funds as well as the disbursement to the student. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend that financial aid staff take greater care in computing the Return of Title IV calculation to ensure accuracy of the calculation and amount of aid to be returned to the student, if any. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name:Student Financial Aid Cluster CFDA # 84.268- Federal Direct Student Loans Special Tests and Provisions- Return of Title IV Funds Significant Deficiency in Internal Controls over Compliance and Noncompliance Finding Summary: One out of the 8 students tested who had withdrawn during the year and underwent a Return of Title IV calculation had not received the correct reimbursement. Responsible Individuals : Amber Brockel, Director of Financial Aid Corrective Action Plan : The student identified during testing had an incorrect withdrawal date used on the Return to Title IV calculation. The date used was from an email request for information on last dated or engagement and was inadvertently used on the calculation . The incorrect date used did not require any funds to be returned to the Department of Education as it was past the 60% mark of the term. Once the error was identified,the correct last date of engagement resulted in Pell Grant funds required to be returned to the Department of Education. The Office of Financial Aid made the necessary correction and returned the appropriate funds to the Department of Education . Currently,the Director of Financial Aid reviews the Return to Title IV calculation for correct dates and information. We have also implemented, as a secondary check, weekly meetings between the Registrar's Office and the Office of Financial Aid to confirm the last date of engagement and withdraw dates on all withdrawals to ensure that correct and consistent dates are being used for Return to Title IV calcu lations and enrollment reporting. The Office of Financial Aid also utilizes ongoing training regarding Return to Title IV via NASFAA webinars, FSA and State Association Conferences, as well as other available resources. Anticipated Completion Date: August 1,2019
2018-002
One out of the 8 students tested who were eligible for a post-withdrawal disbursement during the year had not received their disbursement. Cause: The error was caused by a lack of oversight in disbursing the post-withdrawal funds. Effect: These errors can lead to students not receiving the post-withdrawal disbursement. Questioned Costs: None Context/Sampling: A nonstatistical sample of 8 students who withdrew during the school year and had a return of Title IV funds calculation completed out of a population of 29 students were selected for testing the calculation of the return of the Title IV funds as well as the disbursement to the student. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend that financial aid staff take greater care to ensure appropriate, timely, and correct post-withdrawal disbursement is given to the student, if any. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2018-2019 Award Year Special Tests and Provisions ? Return of Title IV Funds ? Post-withdrawal Disbursements Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR section 668.22 provides the criteria and guidance for the treatment of Title IV funds when a student withdrawals. Condition: One out of the 8 students tested who were eligible for a post-withdrawal disbursement during the year had not received their disbursement. Cause: The error was caused by a lack of oversight in disbursing the post-withdrawal funds. Effect: These errors can lead to students not receiving the post-withdrawal disbursement. Questioned Costs: None Context/Sampling: A nonstatistical sample of 8 students who withdrew during the school year and had a return of Title IV funds calculation completed out of a population of 29 students were selected for testing the calculation of the return of the Title IV funds as well as the disbursement to the student. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend that financial aid staff take greater care to ensure appropriate, timely, and correct post-withdrawal disbursement is given to the student, if any. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268- Federal Direct Student Loans Special Tests and Provisions- Return of Title IV Funds Significant Deficiency in Internal Controls over Compliance and Noncompliance Finding Summary : One out of the 8 students tested who were eligible for a post -withdrawal disbursement during the year had not received their disbursement. Responsible Individuals: Amber Brockel,Director of Financial Aid Corrective Action Plan : The student identified during testing withdrew and earned a post withdrawal disbursement of Pell Grant funds . The Return to Title IV calculation and subsequent post withdrawal disbursement calculation were done correctly,but the post withdrawal disbursement check was not issued to the student. The Director of Financial Aid and the staff accountant in charge of accounts payable met and determined that during that time,the Student Accounts refund batch was only being pulled for specific terms and not overall, which resulted in the refund not being sent out . The staff accountant in charge of accounts payable is now pulling the refund batch overall instead of only for the term . They are also doing a second check of refunds going out by looking at individual ledgers to ensure that the refund has generated and that the ledger is correctly reflecting it as well as doing a monthly check for any credit balances that have not been refunded to the student. Anticipated Completion Date: July 26, 2019
2018-002
One out of the 22 students selected for testing received financial aid fund disbursements prior to verification being completed. Cause: The error was caused by a lack of oversight when aid was being disbursed to students. Effect: The errors can lead to aid being disbursed to students who are not eligible or incorrect amounts of aid disbursed. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students were selected for testing and, out of the 60 students, 22 students were flagged for verification and, subsequently, were selected for testing of verification requirements. Repeat Finding from Prior Year(s): No Recommendation: We recommend that financial aid staff take greater care in verifying student information that was selected by ED prior to disbursement of financial aid. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2018-2019 Award Year Special Test and Provisions ? Verification Significant Deficiency in Internal Controls over Compliance and Noncompliance Criteria: 34 CFR sections 668.51 through 668.61 sets forth the criteria for verifying financial aid applicant information. Condition: One out of the 22 students selected for testing received financial aid fund disbursements prior to verification being completed. Cause: The error was caused by a lack of oversight when aid was being disbursed to students. Effect: The errors can lead to aid being disbursed to students who are not eligible or incorrect amounts of aid disbursed. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students were selected for testing and, out of the 60 students, 22 students were flagged for verification and, subsequently, were selected for testing of verification requirements. Repeat Finding from Prior Year(s): No Recommendation: We recommend that financial aid staff take greater care in verifying student information that was selected by ED prior to disbursement of financial aid. Views of Responsible Officials: Management agrees with the finding.
Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268- Federal Direct Student Loans Special Tests and Prov isio ns- Verification Significant Deficiency in Internal Controls over Compliance and Noncompliance Finding Summary: One out of 22 students selected for testing received financial aid disbursements prior to verification being completed. Responsible Individuals: Amber Brockel, Director of Financial Aid Corrective Action Plan: The student identified during testing had not completed the verification process and had Direct Loans disbursed to their account . The Financial Aid staff have reviewed the guidelines from the Department of Education on verification completion and allowable disbursements of federal aid. The Office of Financial Aid will continue to attend training regarding verif ication via webinars, NASFAA and state author ized events, and FSA Conferences . The Office of Financial Aid is also implementing a cross check process between our student information system and our third party servicer for verification, lnceptia. This will ensure that all students who are selected for verification have completed the verification process prior to disbursement of federal aid. Anticipated Completion Date: November 25, 2019
Presentation College did not perform a formal risk assessment as required. Consequently, safeguards were not documented based on identified risks. Cause: The College?s designated individual to coordinate the information security program is aware of the requirements. However, the risk assessment was not complete as of June 30, 2019. Effect: We were unable to determine the risks identified and the related safeguard for each risk identified. Questioned Costs: None reported Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: No Recommendation: We recommend performing a risk assessment that addresses employee training and management; information systems; and detecting, preventing, and responding to attacks as noted in 16 CFR Section 314.4. Based on the risk assessment, safeguards should be documented based on specific risks identified and clearly linked to specific risks identified. Views of Responsible Officials: Management agrees with the finding
Show full finding ▾Hide full finding ▴Department of Education Student Financial Aid Cluster CFDA # 84.268 ? Federal Direct Student Loans 2018-2019 Award Year Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security Material Weakness in Internal Control over Compliance and Noncompliance Criteria: 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). 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. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition: Presentation College did not perform a formal risk assessment as required. Consequently, safeguards were not documented based on identified risks. Cause: The College?s designated individual to coordinate the information security program is aware of the requirements. However, the risk assessment was not complete as of June 30, 2019. Effect: We were unable to determine the risks identified and the related safeguard for each risk identified. Questioned Costs: None reported Context/Sampling: Sampling was not used. Repeat Finding from Prior Year: No Recommendation: We recommend performing a risk assessment that addresses employee training and management; information systems; and detecting, preventing, and responding to attacks as noted in 16 CFR Section 314.4. Based on the risk assessment, safeguards should be documented based on specific risks identified and clearly linked to specific risks identified. Views of Responsible Officials: Management agrees with the finding
Finding 2019-004 Federal Agency Name: Department of Education Program Name:Student Financial Aid Cluster CFDA # 84.268- Federal Direct Student Loans Special Tests and Provisions- Gramm-Leach- Biiley Act- Student Information Security Material Weakness in Internal Controls over Compliance and Noncompliance Finding Summary: Presen tation College has not prepared aformal risk assessment as required by the Act, as well as formally identify safeguards to address identified risks resulting from the risk assessment performed. Responsible Individuals: Marcus Garstecki,V P of Enrollment,Student Affairs, Marketing, IT Corrective Action Plan: The College is currently in transition and searching for a new Director of IT. Part of the job requireme nts for the new director will be to develop a formal risk assessment plan, which meet the requirements for student information security. The plan will identify any potential risks or threats and how to properly safeguard the College against these risks. This plan will be formally documented and will include annual data security checks as well as education and training on security risks and an annual assessment of awareness of potential security threats such as phishing attacks. We are currently researching best practices regarding the GLB Act and regulatory guidance surrounding it to assist the new Director of IT in preparing the formal risk assessment. Anticipated Completion Date: March 2, 2020
FAC accepted this audit on January 1, 2019 — management decision was due July 1, 2019.
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2017-001
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Show full finding ▾Hide full finding ▴FAC accepted this audit on October 10, 2017 — management decision was due April 10, 2018.
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2016-001
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FAC accepted this audit on November 16, 2016 — management decision was due May 16, 2017.
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