EIN: 470376525
UEI: K17GVVEWF354
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (37 days from today).
What is a management decision? →Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: It was identified that the College did not have effective internal controls to ensure all graduate data was submitted to National Student Loan Data System (NSLDS) on a timely basis. During the audit over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 60 selected whose enrollment change dates were not timely reported to the NSLDS. For three selections, the students were a part of the College’s 3+1 program which required graduate dates to be manually updated in NSLDS. The College set reminders to update the data manually, however, those reminders were set at 61 days instead of the required 60 days. These three enrollment changes were accurately reported to NSLDS. For two selections, these students were May 2025 graduates that were reported to NSLDS with other May 2025 graduates on a timely basis but due to system errors with information transferred, were marked at “W” within the NSLDS system. Once identified in error during the audit, the information for these two students was updated within NSLDS in October 2025 by the College. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not ensure reminders on manually updated graduate information were set to ensure timely reporting to NSLDS. Further, error reports were not reviewed and a final reconciliation was not performed to ensure all graduates were accurately reported within NSLDS. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of improving controls over reviewing the error reports and remin
Show full finding ▾Hide full finding ▴Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: It was identified that the College did not have effective internal controls to ensure all graduate data was submitted to National Student Loan Data System (NSLDS) on a timely basis. During the audit over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 60 selected whose enrollment change dates were not timely reported to the NSLDS. For three selections, the students were a part of the College’s 3+1 program which required graduate dates to be manually updated in NSLDS. The College set reminders to update the data manually, however, those reminders were set at 61 days instead of the required 60 days. These three enrollment changes were accurately reported to NSLDS. For two selections, these students were May 2025 graduates that were reported to NSLDS with other May 2025 graduates on a timely basis but due to system errors with information transferred, were marked at “W” within the NSLDS system. Once identified in error during the audit, the information for these two students was updated within NSLDS in October 2025 by the College. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not ensure reminders on manually updated graduate information were set to ensure timely reporting to NSLDS. Further, error reports were not reviewed and a final reconciliation was not performed to ensure all graduates were accurately reported within NSLDS. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of improving controls over reviewing the error reports and remin
CORRECTIVE ACTION The Registrar and the Assistant Director of Financial Aid will be included in the receipt of the graduation file. The graduation file will be uploaded in the National Student Clearinghouse (NSC) and the Registrar will alert the Financial Aid office when submitted. The Registrar will confirm in NSC the file was uploaded with no errors for campus level and program level reporting. The Office of Financial Aid will add to its current procedure to request additional reports from NSLDS (campus level and program level), 3 weeks after the file has been uploaded to NSC; to show graduates and withdrawal information reported at the program and campus levels. The Dean of Enrollment and Financial Aid will also set a calendar alert for comparing the degree verify file against the NSLDS reports for discrepancies. Should discrepancies arise, the Assistant Director of Financial Aid and the Registrar will work together to address and correct the issues before 60 days post-graduation. Anticipated Date of Completion: In place for the 2025-2026 academic year.
FAC accepted this audit on December 13, 2024 — management decision was due June 13, 2025.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2023 through June 30, 2024 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: It was identified that the College did not have effective internal controls over the review over program level data changes submitted to National Student Loan Data System (NSLDS) for students who withdrew. During testwork over enrollment reporting, we selected 18 students who withdrew from the College during the fiscal year. We identified 5 students out of 18 selected whose enrollment change dates were not accurately reported to the NSLDS at the program level. For all selections, the enrollment change dates were accurately reported to NSLDS at the campus level. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not review the listing of changes submitted to NSLDS at the program level, which caused the enrollment change dates for students who withdrew to not be reported accurately at the program level. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing the accuracy of program level enrollment status changes to ensure that they are appropriately reported to NSLDS.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2023 through June 30, 2024 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 690.83(b)(2) and 2 CFR 685.309 requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: It was identified that the College did not have effective internal controls over the review over program level data changes submitted to National Student Loan Data System (NSLDS) for students who withdrew. During testwork over enrollment reporting, we selected 18 students who withdrew from the College during the fiscal year. We identified 5 students out of 18 selected whose enrollment change dates were not accurately reported to the NSLDS at the program level. For all selections, the enrollment change dates were accurately reported to NSLDS at the campus level. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not review the listing of changes submitted to NSLDS at the program level, which caused the enrollment change dates for students who withdrew to not be reported accurately at the program level. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 690.83(b)(2) and 2 CFR 685.309. View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing the accuracy of program level enrollment status changes to ensure that they are appropriately reported to NSLDS.
Finding 2024-001 Finding Title: Student Financial Assistance Cluster Name of Contact Person: Traci Boeve, Director of Financial Aid Corrective Action: The Assistant Registrar and the Office of Financial Aid will continue to be included in the receipt of the graduation file. The Assistant Registrar will confirm in NSC (National Student Clearinghouse) the file was uploaded with no errors for campus level and program level reporting. The Office of Financial Aid will add to its current procedure by requesting an additional report from NSLDS to show graduates and withdrawal information reported at the program level. Anticipated Date of Completion: In place for 2024-2025 school year
FAC accepted this audit on December 1, 2023 — management decision was due June 1, 2024.
Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.
Show full finding ▾Hide full finding ▴Finding 2023-003 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.268 and 84.063 Grant Award Period: July 1, 2022 through June 30, 2023 Grant Identification Numbers: N/A Compliance Requirement: Enrollment Reporting Criteria: 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant has been made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-timebasis for the period for which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During testwork over enrollment reporting, we selected 39 students who graduated from the College during the fiscal year. We identified 5 students out of 39 selected whose enrollment status was not reported to the National Student Loan Data System (NSLDS). Management performed an additional analysis and identified that the enrollment status for 46 out of 179 students who graduated in fiscal year 2023 were not reported to NSLDS. Further, it was identified that the College did not have effective internal controls over enrollment reporting in accordance with 2 CFR 200.303. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None identified Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College submitted its listing of individuals who graduated to Clearinghouse to upload to NSLDS. However, the College did not review the listing of exceptions from Clearinghouse related to the students whose status changes were not uploaded to NSLDS, which caused the enrollment changes for students who graduated to not be reported in accordance with federal requirements. This caused students to not be reported to NDLDS until the audit. Recommendation: We recommend the College enhance its internal control to ensure that the College has effective internal controls in place to ensure that the College conforms to required enrollment reporting as set forth in 2 CFR 682.309(b)(2) and 2 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of implementing controls over reviewing exception reports for submissions to Clearinghouse to ensure that all individuals with enrollment status changes are appropriately reported to NSLDS.
Finding 2023-003 Finding Title: Student Financial Assistance Cluster Name of Contact Person: Traci Boeve, Director of Financial Aid Corrective Action: Hastings College will add additional staff as a control to the current process. The Assistant Registrar and the Office of Financial Aid will be included in the receipt of the graduation file. The Assistant Registrar will confirm in NSC (National Student Clearinghouse) the file was uploaded with no errors. The Office of Financial Aid will also request a report from NSLDS, which can be compared to the file that was directly uploaded to NSC. Anticipated Date of Completion: In place for 2023-2024 school year.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund - Institutional Portion (Assistance Listing No. 84.425F)Grant Award Period: July 1, 2021 through June 30, 2022 Grant Identification Numbers: P425F203954 ? 20A Compliance Requirement: Procurement, Suspension and Debarment Criteria: 2 CFR 200.318(a) requires the non-Federal entity to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implemented at 2 CFR 180.300. 2 CFR 180.300 specifies that before entering into a covered transaction with another person at the next lower tier, the entity must verify that the counterparty with whom they intend to do business is not excluded or disqualified. 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure compliance with procurement, suspension and debarment standards. Conditions Found: During the audit, it was identified that the College did not have a procurement policy in order to comply with 2 CFR 200.318(a). As a result of the lack of a policy, expenditures were made that were not in compliance with the procurement requirements of 2 CFR 200.317 through 2 CFR 200.327. Additionally, it was identified that the College did not obtain evidence that the expenditures made during the period were in compliance with the suspension and debarment requirements of 2 CFR 200.214 and 2 CFR 180.300. Further, it was identified that the College did not have effective internal controls over procurement, suspension and debarment in accordance with 2 CFR 200.303. Total expenditures for 84.425F that were subject to procurement, suspension and debarment compliance requirements were $847,652. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Not determinable Repeat Finding: This finding is a repeat finding in the immediately prior audit. In the prior year, this was reported as finding 2021-001. Cause and Effect: The College did not perform procedures to evidence that the transactions entered into were with counterparties which met the requirements of 2 CFR 200.214 and 2 CFR 180.300. The College did not have an effective system of internal control in place to ensure the procurement, suspension and debarment compliance requirements in 2 CFR 200.317 through 200.327 and 2 CFR 200.214 and 2 CFR 180.300. The College does not typically expend federal awards that are subject to the Uniform Guidance procurement requirements, and as such, management did not have policies in place prior to receiving these federal awards to comply with procurement, suspension and debarment compliance requirements. In response to the prior year finding, management is in process of implementing procurement policies to meet the requirements of 2 CFR sections 200.317 through 200.327. Recommendation: We recommend the College enhance its internal control to ensure that the College has a policy and effective internal controls in place to ensure that the College conforms to required federal procurement, suspension and debarment procedures. View of Responsible Officials: We concur with the finding and are in the process of finalizing policies and procedures to comply with procurement, suspension and debarment standards. Beginning in April 2022, in response to the prior year finding, the College began to ensure vendors were not suspended and debarred for all HEERF funds, including reviewing prior vendors with which HEERF funds were expended. Further, management began obtaining quotes for certain purchases that are being reimbursed by HEERF funds. Consistent with our corrective action plan, we implemented formal written policies and procedures during fiscal year 2023.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Title: COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund - Institutional Portion (Assistance Listing No. 84.425F)Grant Award Period: July 1, 2021 through June 30, 2022 Grant Identification Numbers: P425F203954 ? 20A Compliance Requirement: Procurement, Suspension and Debarment Criteria: 2 CFR 200.318(a) requires the non-Federal entity to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implemented at 2 CFR 180.300. 2 CFR 180.300 specifies that before entering into a covered transaction with another person at the next lower tier, the entity must verify that the counterparty with whom they intend to do business is not excluded or disqualified. 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure compliance with procurement, suspension and debarment standards. Conditions Found: During the audit, it was identified that the College did not have a procurement policy in order to comply with 2 CFR 200.318(a). As a result of the lack of a policy, expenditures were made that were not in compliance with the procurement requirements of 2 CFR 200.317 through 2 CFR 200.327. Additionally, it was identified that the College did not obtain evidence that the expenditures made during the period were in compliance with the suspension and debarment requirements of 2 CFR 200.214 and 2 CFR 180.300. Further, it was identified that the College did not have effective internal controls over procurement, suspension and debarment in accordance with 2 CFR 200.303. Total expenditures for 84.425F that were subject to procurement, suspension and debarment compliance requirements were $847,652. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Not determinable Repeat Finding: This finding is a repeat finding in the immediately prior audit. In the prior year, this was reported as finding 2021-001. Cause and Effect: The College did not perform procedures to evidence that the transactions entered into were with counterparties which met the requirements of 2 CFR 200.214 and 2 CFR 180.300. The College did not have an effective system of internal control in place to ensure the procurement, suspension and debarment compliance requirements in 2 CFR 200.317 through 200.327 and 2 CFR 200.214 and 2 CFR 180.300. The College does not typically expend federal awards that are subject to the Uniform Guidance procurement requirements, and as such, management did not have policies in place prior to receiving these federal awards to comply with procurement, suspension and debarment compliance requirements. In response to the prior year finding, management is in process of implementing procurement policies to meet the requirements of 2 CFR sections 200.317 through 200.327. Recommendation: We recommend the College enhance its internal control to ensure that the College has a policy and effective internal controls in place to ensure that the College conforms to required federal procurement, suspension and debarment procedures. View of Responsible Officials: We concur with the finding and are in the process of finalizing policies and procedures to comply with procurement, suspension and debarment standards. Beginning in April 2022, in response to the prior year finding, the College began to ensure vendors were not suspended and debarred for all HEERF funds, including reviewing prior vendors with which HEERF funds were expended. Further, management began obtaining quotes for certain purchases that are being reimbursed by HEERF funds. Consistent with our corrective action plan, we implemented formal written policies and procedures during fiscal year 2023.
Finding 2022-01 Federal Program Title: Education Stabilization Fund ?Higher Education Emergency Relief Fund Compliance Requirement: Procurement, Suspension and Debarment Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College developed and implemented a procurement policy which addressed Uniform Guidance Procurement, Suspension and Debarment requirements. Date of Completion: January 5, 2023
2021-001
FAC accepted this audit on March 10, 2022 — management decision was due September 10, 2022.
Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund (Assistance Listing No. 84.425F) Compliance Requirement: Procurement, Suspension and Debarment Criteria: 2 CFR 200.318(a) requires the non-Federal entity to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implemented at 2 CFR 180.300. 2 CFR 180.300 specifies that before entering into a covered transaction with another person at the next lower tier, the entity must verify that the counterparty with whom they intend to do business is not excluded or disqualified. 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure compliance with procurement, suspension and debarment standards. Conditions Found: During testwork, it was identified that the College did not have a procurement policy in order to comply with 2 CFR 200.318(a). As a result of the lack of a policy, expenditures were made that were not in compliance with the procurement requirements of 2 CFR 200.317 through 2 CFR 200.327. Additionally, it was identified that the College did not obtain evidence that the expenditures made during the period were in compliance with the suspension and debarment requirements of 2 CFR 200.214 and 2 CFR 180.300. Further, it was identified that the College did not have effective internal controls over procurement, suspension and debarment in accordance with 2 CFR 200.303. For procurement, suspension and debarment compliance testwork, 4 expenditures were selected for testwork, which totaled $315,444, which generated $31,544 of indirect costs. Total expenditures for 84.425F that were subject to procurement, suspension and debarment compliance requirements were $394,232 and an additional $39,423 was charged as indirect costs. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Not determinable Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not perform procedures to evidence that the transactions entered into were with counterparties which met the requirements of 2 CFR 200.214 and 2 CFR 180.300. The College did not have an effective system of internal control in place to ensure the procurement, suspension and debarment compliance requirements in 2 CFR 200.317 through 200.327 and 2 CFR 200.214 and 2 CFR 180.300. The College does not typically expend federal awards that are subject to the Uniform Guidance procurement requirements, and as such, management did not have policies in place prior to receiving these federal awards to comply with procurement, suspension and debarment compliance requirements. Management failed to identify the need for these procurement policies to meet the requirements of 2 CFR sections 200.317 through 200.327. The College did follow the College?s internal policies and procedures in these procurements; however, those policies were not in compliance with the requirements of 2 CFR sections 200.317 through 200.327, or 2 CFR 200.214 and 2 CFR 180.300, which resulted in material noncompliance with the procurement, suspension and debarment compliance requirement. Recommendation: We recommend the College enhance its internal control to ensure that the College has a policy and effective internal controls in place to ensure that the College conforms to required federal procurement, suspension and debarment procedures. View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to comply with procurement, suspension and debarment standards.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund (Assistance Listing No. 84.425F) Compliance Requirement: Procurement, Suspension and Debarment Criteria: 2 CFR 200.318(a) requires the non-Federal entity to have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200.214 states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implemented at 2 CFR 180.300. 2 CFR 180.300 specifies that before entering into a covered transaction with another person at the next lower tier, the entity must verify that the counterparty with whom they intend to do business is not excluded or disqualified. 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure compliance with procurement, suspension and debarment standards. Conditions Found: During testwork, it was identified that the College did not have a procurement policy in order to comply with 2 CFR 200.318(a). As a result of the lack of a policy, expenditures were made that were not in compliance with the procurement requirements of 2 CFR 200.317 through 2 CFR 200.327. Additionally, it was identified that the College did not obtain evidence that the expenditures made during the period were in compliance with the suspension and debarment requirements of 2 CFR 200.214 and 2 CFR 180.300. Further, it was identified that the College did not have effective internal controls over procurement, suspension and debarment in accordance with 2 CFR 200.303. For procurement, suspension and debarment compliance testwork, 4 expenditures were selected for testwork, which totaled $315,444, which generated $31,544 of indirect costs. Total expenditures for 84.425F that were subject to procurement, suspension and debarment compliance requirements were $394,232 and an additional $39,423 was charged as indirect costs. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Not determinable Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not perform procedures to evidence that the transactions entered into were with counterparties which met the requirements of 2 CFR 200.214 and 2 CFR 180.300. The College did not have an effective system of internal control in place to ensure the procurement, suspension and debarment compliance requirements in 2 CFR 200.317 through 200.327 and 2 CFR 200.214 and 2 CFR 180.300. The College does not typically expend federal awards that are subject to the Uniform Guidance procurement requirements, and as such, management did not have policies in place prior to receiving these federal awards to comply with procurement, suspension and debarment compliance requirements. Management failed to identify the need for these procurement policies to meet the requirements of 2 CFR sections 200.317 through 200.327. The College did follow the College?s internal policies and procedures in these procurements; however, those policies were not in compliance with the requirements of 2 CFR sections 200.317 through 200.327, or 2 CFR 200.214 and 2 CFR 180.300, which resulted in material noncompliance with the procurement, suspension and debarment compliance requirement. Recommendation: We recommend the College enhance its internal control to ensure that the College has a policy and effective internal controls in place to ensure that the College conforms to required federal procurement, suspension and debarment procedures. View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to comply with procurement, suspension and debarment standards.
Finding 2021-01 Federal Program Title: Education Stabilization Fund ?Higher Education Emergency Relief Fund Compliance Requirement: Procurement, Suspension and Debarment Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College will develop and implement a procurement policy which addresses Uniform Guidance Procurement, Suspension and Debarment requirements. Anticipated Date of Completion: May 1, 2022
Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund (Assistance listing No. 84.425F) Compliance Requirement: Allowable Costs/Cost Principles Criteria: According to 2 CFR 200.414(f), any non-Federal entity that does not have a current negotiated (including provisional) rate, may elect to charge a de minimis rate of 10% of modified total direct costs which may be used indefinitely. No documentation is required to justify the 10% de minimis indirect cost rate. Per 2 CFR 200.1 definitions: Modified total direct costs (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs and with the approval of the cognizant agency for indirect costs. Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000. Supplies means all tangible personal property other than those described in the definition of equipment in this section. A computing device is a supply if the acquisition cost is less than the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000, regardless of the length of its useful life. Further, as noted in the 2 CFR Part 200, Compliance Supplement dated July 2021, reasonable direct administrative costs and indirect costs at an institution?s approved negotiated indirect cost rate may be charged against Assistance Listing 84.425F (the Institutional portion). An institution may not apply an indirect cost rate to its estimated amount of lost revenue. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure compliance with allowable costs/cost principles standards. Conditions Found: The College utilized the de minimis indirect cost rate of 10% as it had no negotiated rate to determine indirect costs to be charged against this program. During testwork, it was found that the indirect cost rate was applied to certain expenditures that did not qualify as MTDC and that the College did not have an effective system of internal control in place to ensure indirect costs were appropriately applied. Specifically, the indirect rate was applied to lost revenue and was applied to equipment that was capitalized by the College resulting in $78,443 of indirect costs that were unallowable. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $78,443 Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not have an effective system of internal control in place to ensure modified total direct costs were appropriately determined in accordance with the definition in 2 CFR 200.1, which led to material noncompliance with allowable costs/cost principles compliance requirements. Recommendation: We recommend the College enhance its internal control to ensure that the College determines indirect costs in compliance with 2 CFR 200.1. View of Responsible Officials: We concur with the finding and are in the process of developing new controls to comply with the determination of indirect costs.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund (Assistance listing No. 84.425F) Compliance Requirement: Allowable Costs/Cost Principles Criteria: According to 2 CFR 200.414(f), any non-Federal entity that does not have a current negotiated (including provisional) rate, may elect to charge a de minimis rate of 10% of modified total direct costs which may be used indefinitely. No documentation is required to justify the 10% de minimis indirect cost rate. Per 2 CFR 200.1 definitions: Modified total direct costs (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs and with the approval of the cognizant agency for indirect costs. Equipment means tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000. Supplies means all tangible personal property other than those described in the definition of equipment in this section. A computing device is a supply if the acquisition cost is less than the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000, regardless of the length of its useful life. Further, as noted in the 2 CFR Part 200, Compliance Supplement dated July 2021, reasonable direct administrative costs and indirect costs at an institution?s approved negotiated indirect cost rate may be charged against Assistance Listing 84.425F (the Institutional portion). An institution may not apply an indirect cost rate to its estimated amount of lost revenue. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure compliance with allowable costs/cost principles standards. Conditions Found: The College utilized the de minimis indirect cost rate of 10% as it had no negotiated rate to determine indirect costs to be charged against this program. During testwork, it was found that the indirect cost rate was applied to certain expenditures that did not qualify as MTDC and that the College did not have an effective system of internal control in place to ensure indirect costs were appropriately applied. Specifically, the indirect rate was applied to lost revenue and was applied to equipment that was capitalized by the College resulting in $78,443 of indirect costs that were unallowable. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $78,443 Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: The College did not have an effective system of internal control in place to ensure modified total direct costs were appropriately determined in accordance with the definition in 2 CFR 200.1, which led to material noncompliance with allowable costs/cost principles compliance requirements. Recommendation: We recommend the College enhance its internal control to ensure that the College determines indirect costs in compliance with 2 CFR 200.1. View of Responsible Officials: We concur with the finding and are in the process of developing new controls to comply with the determination of indirect costs.
Finding 2021-02 Federal Program Title: Education Stabilization Fund ? Higher Education Emergency Relief Fund Compliance Requirement: Allowable Costs / Costs Principles Name of Contact Person: Lynn Feeken, Financial Controller Corrective Action: The College will identify allowable costs to replace the disallowed indirect costs and revise the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion accordingly. If indirect costs are included in the American Rescue Plan ? Higher Education Emergency Relief Fund III expenditures, the Business Office will confirm that the 10% de minimis indirect cost rate is applied to the modified total direct costs. Anticipated Date of Completion: May 17, 2022
FAC accepted this audit on September 27, 2021 — management decision was due March 27, 2022.
Finding 2020-001 Program Information: Federal Agency: U.S. Department of Education ? Direct Programs Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.268 and 84.063) Grant Award Period: July 1, 2019 through June 30, 2020 Grant Identification Numbers: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: 34 CFR Section 685.309(b)(2) and 34 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testwork, we selected 60 students who either withdrew or graduated from Hastings College (the College) during the fiscal year. We identified 10 students out of the 60 selected whose student enrollment status was not reported accurately to the National Student Loan Data System (NSLDS) and 12 students who were not reported timely to NSLDS. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College began a new academic calendar with several blocks contained within each semester. The policies and procedures in place at the College were not adequately designed to ensure timely and accurately reporting for various occurrences related to student withdrawals due to this new block structure. This caused students who withdrew earlier in the semester to be reported outside the federal requirements and for withdraw dates to be reported as the end of the semester instead of student?s actual withdraw date. Recommendation: We recommend College enhance its internal control to ensure that the College has effective internal controls in place to ensure that accurate enrollment status data is being submitted for students who withdraw on a timely basis, as set forth in 34 Section 685.309(b)(2) and 34 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to address the timely filing of all student status changes that could occur throughout the year.
Show full finding ▾Hide full finding ▴Finding 2020-001 Program Information: Federal Agency: U.S. Department of Education ? Direct Programs Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.268 and 84.063) Grant Award Period: July 1, 2019 through June 30, 2020 Grant Identification Numbers: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: 34 CFR Section 685.309(b)(2) and 34 CFR 690.83(b)(2) requires participating schools in the Direct Loan Program and Pell Program to notify the Secretary of Education if a Direct Loan or Pell grant had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Conditions Found: During our testwork, we selected 60 students who either withdrew or graduated from Hastings College (the College) during the fiscal year. We identified 10 students out of the 60 selected whose student enrollment status was not reported accurately to the National Student Loan Data System (NSLDS) and 12 students who were not reported timely to NSLDS. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Repeat Finding: This finding is not a repeat finding in the immediately prior audit. Cause and Effect: During the year, the College began a new academic calendar with several blocks contained within each semester. The policies and procedures in place at the College were not adequately designed to ensure timely and accurately reporting for various occurrences related to student withdrawals due to this new block structure. This caused students who withdrew earlier in the semester to be reported outside the federal requirements and for withdraw dates to be reported as the end of the semester instead of student?s actual withdraw date. Recommendation: We recommend College enhance its internal control to ensure that the College has effective internal controls in place to ensure that accurate enrollment status data is being submitted for students who withdraw on a timely basis, as set forth in 34 Section 685.309(b)(2) and 34 CFR 690.83(b)(2). View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to address the timely filing of all student status changes that could occur throughout the year.
Finding 2020-001 ? Student Financial Assistance Cluster ? Special Tests and Provisions ? Enrollment Reporting Name of Contact Person: Jim Boeve, Registrar ITEM 1 ? With our academic semester made up of three `Blocks?, a student may withdraw from the College after earning credit in one or both of the first two Blocks; the Student Information System recognizes the student as `part-time? and the withdrawal date is defaulted to last day of term/semester, rather than the actual date of withdrawal. Corrective Action: The College has established a document shared by the offices of: The Registrar, Financial Aid, Institutional Effectiveness, and Student Accounts. This document contains information on student withdrawals, including key dates. This allows these offices to periodically and systematically check information that our Student Information System automatically enters, and override it, if necessary. Anticipated Date of Completion: In place for 2020-2021 school year ITEM 2 ? A student is not enrolled for one of the three Blocks that make up our semester, then does not return for the succeeding Block (for which they are registered). Depending on start and end dates of the Blocks, meeting the window for reporting a student as withdrawn can be missed. Corrective Action: The Office of the Registrar and the Financial Aid Office are scheduling enrollment reporting dates to: a) better fit with Hastings College?s start dates and drop/add deadlines; and b) align more appropriately with National Student Loan Data System (NSLDS) dates. Due to the fact that the Enrollment Reporting of our Power Campus product was not designed with Block scheduling in mind, the Financial Aid office will make manual corrections (as needed, at student, campus, and/or program level) directly into NSLDS. Anticipate Date of Completion: Dates determined at the beginning of each semester, beginning with fall semester, 2021. Manual updates to be made based on those dates.
FAC accepted this audit on February 20, 2020 — management decision was due August 20, 2020.
Finding 2019-001 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.007, 84.033, 84.038, 84.379, 84.268, and 84.063) Grant Identification Numbers: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: 34 CFR Section 685.309(b)(2) requires participating schools in the Direct Loan Program to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. Condition Found: During our testwork, we selected 40 students out of 249 who either withdrew or graduated from Hastings College during the fiscal year. We identified 7 students out of the 40 selected whose student enrollment status was not reported timely to the National Student Loan Data System (NSLDS). Sampling: The sample was not intended to be, and was not, a statistically valid sample Questioned Costs: None Repeat Finding: No Cause and Effect: The policies and procedures in place at the College were not adequately designed to ensure timely reporting for various occurrences related to student withdrawals. Recommendation: We recommend that the College update their policies and procedures to ensure all student status changes are reported to NSLDS in a timely manner. View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to address the timely filing of all student status changes that could occur throughout the year.
Show full finding ▾Hide full finding ▴Finding 2019-001 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.007, 84.033, 84.038, 84.379, 84.268, and 84.063) Grant Identification Numbers: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: 34 CFR Section 685.309(b)(2) requires participating schools in the Direct Loan Program to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. Condition Found: During our testwork, we selected 40 students out of 249 who either withdrew or graduated from Hastings College during the fiscal year. We identified 7 students out of the 40 selected whose student enrollment status was not reported timely to the National Student Loan Data System (NSLDS). Sampling: The sample was not intended to be, and was not, a statistically valid sample Questioned Costs: None Repeat Finding: No Cause and Effect: The policies and procedures in place at the College were not adequately designed to ensure timely reporting for various occurrences related to student withdrawals. Recommendation: We recommend that the College update their policies and procedures to ensure all student status changes are reported to NSLDS in a timely manner. View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to address the timely filing of all student status changes that could occur throughout the year.
Finding: 2019-001 Name of Contact Person(s): Traci Boeve, Director of Financial Aid Compliance Requirement: Special Test- Enrollment Reporting Corrective Action: Effective for the 2019-2020 school year, Hastings College has made the following changes: - Hastings College no longer has a January term, which created difficulty in completing reporting during the allotted days. - Hastings College implemented an August (2020) and a December (2019) graduation conferral so the gaps between the last day of attendance and graduation are timely and accurate. These graduations in December, May and August will continue in subsequent years. - The schedule for reporting to the Clearinghouse was examined to ensure that it aligned with the college calendar to meet reporting deadlines. Anticipated date of completion: Already Completed
Finding 2019-002 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.007, 84.033, 84.038, 84.379, 84.268, and 84.063) Grant Identification Numbers: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: 34 CFR Section 685.309(b)(2) requires participating schools in the Direct Loan Program to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. Condition Found: During our testwork, we selected 40 students out of 249 who either withdrew or graduated from the College during the fiscal year. We identified 1 student out of the 40 selected whose student enrollment status was not reported accurately to the NSLDS. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Repeat Finding: No Cause and Effect: The registrar?s office had inaccurately input the graduating student?s minor in place of the student?s major in the registrar?s IT system. This error resulted in the graduating student not being included in the list of graduates provided by the registrar to the student financial aid office to be uploaded into the NSLDS database. Recommendation: We recommend that the College update their policies and procedures to include a student financial aid review of all graduating students. This review would confirm that the entire graduating population is included in the list provided by the registrar used to update the NSLDS database. View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to address the appropriate inclusion of all graduating students into the NSLDS database.
Show full finding ▾Hide full finding ▴Finding 2019-002 Program Information: Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster (CFDA No. 84.007, 84.033, 84.038, 84.379, 84.268, and 84.063) Grant Identification Numbers: N/A Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: 34 CFR Section 685.309(b)(2) requires participating schools in the Direct Loan Program to notify the Secretary of Education if a Direct Loan had been made to or on behalf of a student who enrolled at the school but ceased to be enrolled on at least half-time basis or has been accepted for enrollment at the school but failed to enroll on at least a half-time basis for the period which the loan was intended. This notification is required to be reported within 30 days, unless a roster will be submitted within 60 days. Condition Found: During our testwork, we selected 40 students out of 249 who either withdrew or graduated from the College during the fiscal year. We identified 1 student out of the 40 selected whose student enrollment status was not reported accurately to the NSLDS. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Repeat Finding: No Cause and Effect: The registrar?s office had inaccurately input the graduating student?s minor in place of the student?s major in the registrar?s IT system. This error resulted in the graduating student not being included in the list of graduates provided by the registrar to the student financial aid office to be uploaded into the NSLDS database. Recommendation: We recommend that the College update their policies and procedures to include a student financial aid review of all graduating students. This review would confirm that the entire graduating population is included in the list provided by the registrar used to update the NSLDS database. View of Responsible Officials: We concur with the finding and are in the process of developing new policies and procedures to address the appropriate inclusion of all graduating students into the NSLDS database.
Finding: 2019-002 Name of Contact Person(s): Traci Boeve, Director of Financial Aid Compliance Requirement: Special Test- Enrollment Reporting Corrective Action: Financial Aid will log into NSLDS and manually fix the individual student record. The Director of Financial Aid has ensured that the individual record has been accurately updated. For subsequent fiscal year, the financial aid office will cross-reference all lists of graduating students to NSLDS, verifying that all graduated students have the appropriate Anticipated date of completion: February 28, 2020
FAC accepted this audit on October 29, 2018 — management decision was due April 29, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on October 23, 2016 — management decision was due April 23, 2017.
GSA_MIGRATION
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