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THE KANSAS CITY COLLEGE AND BIBLE SCHOOL, INC. d/b/a KANSAS CHRISTIAN COLLEGEHigher Education

EIN: 480608889

UEI: KE9BRSM6R5G6

Audited by: CapinCrouse LLC

Oversight agency: 84 [Department of Education]

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Data as of September 2, 2026

THE KANSAS CITY COLLEGE AND BIBLE SCHOOL, INC. d/b/a KANSAS CHRISTIAN COLLEGE7 audit years18 findings13 repeat
7
Audit Years
18
Total Findings
13
Repeat Findings
$1.6M
Federal Awards Expended (FY 2025)

FY 2025-06-30

LOW-RISK AUDITEE$1,622,486 federal awards expendedNo findings recorded this year

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 (28 days from today).

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FY 2024-06-30

$1,419,168 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

FY 2023-06-30

$1,661,571 federal awards expended

FAC accepted this audit on March 23, 2024 — management decision was due September 23, 2024.

2023-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its information security program, security risk assessment and safeguards in light of the updated regulations. Additionally, the College has not implemented sufficient continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, formalized employee and information security staff training, awareness, and skills, or provided a written, annual report to the board covering all required areas. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its information security program, security risk assessment and safeguards in light of the updated regulations. Additionally, the College has not implemented sufficient continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, formalized employee and information security staff training, awareness, and skills, or provided a written, annual report to the board covering all required areas. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The institution concurs with the audit finding of partial compliance and recognizes the need to fully comply with the updated GLBA regulations. The institution is working to acquire additional expertise to guide the development of processes and implementation of procedures to address the deficiencies, better protect consumer PII, and become fully compliant within six months. Person Responsible for Corrective Action Plan: David Carpenter, CFO Anticipated Date of Completion: September 30, 2024

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FY 2022-06-30

$2,078,598 federal awards expended

FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.

2022-002
Special Tests & Provisions
REPEAT OF 2021-004QUESTIONED COSTSOTHER MATTERS

The College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $550 Context: Out of 14 students tested for withdrawal compliance, three students had incorrect R2T4 calculations. The calculations used the incorrect number of completed days or total days. Two of the calculations should have had more Pell Grant returned totaling $295. One of the calculations should have had less Federal Direct Loan returned totaling $255. Cause: Lack of oversight and adequate review. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2021-004 and 2020-003. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over the process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.

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Inaccurate Return of Title IV Funds (R2T4) DEPARTMENT OF EDUCATION ALN #: 84.063 Pell Grants and 84.268 Federal Direct Loans Federal Award Identification: 2021-2022 Award Year Condition: The College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $550 Context: Out of 14 students tested for withdrawal compliance, three students had incorrect R2T4 calculations. The calculations used the incorrect number of completed days or total days. Two of the calculations should have had more Pell Grant returned totaling $295. One of the calculations should have had less Federal Direct Loan returned totaling $255. Cause: Lack of oversight and adequate review. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2021-004 and 2020-003. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over the process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.

Corrective Action Plan

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: A master schedule has been created that includes the starting date, ending date, and break dates for each term. The break dates provided and used previously were not accurate and the master schedule provides the document all departments will use going forward. This will fix the issue involving the incorrect number of days used in the R2T4 calculations. Per the auditor?s recommendations, the institution has hired an experienced professional with over fifteen years of experience in Title IV processing to complete the R2T4 calculations. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: Completed 3/9/2023

Prior Finding References

2021-004

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FY 2021-06-30

$1,884,092 federal awards expended

FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.

2021-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The College did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not sufficiently documented its security risk assessment. Cause: The College has not allocated sufficient resources to address the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Recommendation: We recommend that the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.

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Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063-Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The College did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not sufficiently documented its security risk assessment. Cause: The College has not allocated sufficient resources to address the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Recommendation: We recommend that the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.

Corrective Action Plan

Finding Number: 2021-003 Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: KCC hired a part-time director of IT to help address the deficiencies in this area. A thorough review of GLBA and KCC?s security risk assessment plan and implementation at the department level is in process to ensure student information security and compliance with GLBA. Person Responsible for Corrective Action Plan: (David Carpenter, CFO) Anticipated Date of Completion: October 31, 2022

About Special Tests and Provisions →
2021-004
Special Tests & Provisions
REPEAT OF 2020-003QUESTIONED COSTSOTHER MATTERS

The College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $410 Context: Out of 9 students tested for withdrawal compliance, four students had incorrect R2T4 calculations. The calculations should have used the last day of attendance for the withdrawal date as the College is an attendance taking institution. Two of the calculations should have had more Pell returned totaling $410. One of the calculations should have had $68 more awarded in Pell as a post-withdrawal disbursement. One of the calculations should have had less Pell returned totaling $53. Cause: Lack of oversight and adequate review Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2020-003 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.

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Full finding narrative

Inaccurate Return of Title IV Funds (R2T4) DEPARTMENT OF EDUCATION ALN #: 84.063 Pell Grants and 84.268 Federal Direct Loans Federal Award Identification: 2020-2021 Award Year Condition: The College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $410 Context: Out of 9 students tested for withdrawal compliance, four students had incorrect R2T4 calculations. The calculations should have used the last day of attendance for the withdrawal date as the College is an attendance taking institution. Two of the calculations should have had more Pell returned totaling $410. One of the calculations should have had $68 more awarded in Pell as a post-withdrawal disbursement. One of the calculations should have had less Pell returned totaling $53. Cause: Lack of oversight and adequate review Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2020-003 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.

Corrective Action Plan

Finding Number: 2021-004 Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The corrective action plan provided in the previous audit year?s response and implemented in the 2021 year is working. The corrective action plan identified the implementation of a tracking tool to ensure accurate information is used to populate the R2T4 form. Three of the four findings identified were completed before the corrective action was implemented. The one of the four findings that occurred after the implementation of the tracking tool was do a lack of training with a newly hired staff member. The staff person did not realize the college was required to take attendance. The individual was trained on this at some point during the semester being reviewed. After reviewing the eleven R2T4s completed by this staff member for the period in question, only one other R2T4 was completed with the College listed as not required to take attendance. Person Responsible for Corrective Action Plan: (Wes Brothers, Director of Financial Aid) Anticipated Date of Completion: Complete

Prior Finding References

2020-003

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FY 2020-06-30

$1,466,459 federal awards expended

FAC accepted this audit on July 27, 2021 — management decision was due January 27, 2022.

2020-002
Eligibility
REPEAT OF 2019-002OTHER MATTERS

We tested sixty-three files, fifty-two of which were Pell Grant recipients, and four students did not receive the full amount of their allowed Pell grants. The students were eligible for $9,978, but received $4,435. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-002. Cause: The condition was caused by not paying eligible Pell grants to two students and not paying the proper amount of post-withdrawal disbursements for the other two students. Effect: The result is students did not receive $5,543 of eligible Pell monies. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization credit $5,543 to the students' accounts and increase controls over Pell grants. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-002: UNDERAWARDED PELL GRANTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM CFDA#: 84.063 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested sixty-three files, fifty-two of which were Pell Grant recipients, and four students did not receive the full amount of their allowed Pell grants. The students were eligible for $9,978, but received $4,435. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-002. Cause: The condition was caused by not paying eligible Pell grants to two students and not paying the proper amount of post-withdrawal disbursements for the other two students. Effect: The result is students did not receive $5,543 of eligible Pell monies. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization credit $5,543 to the students' accounts and increase controls over Pell grants. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Per Sec. 668.164(j)(4)(iii), "An institution may not make a late disbursement later than 180 days after the date the institution determines that the student withdrew, as provided in Sec. 668.22, or for a student who did not withdraw, 180 days after the date the student otherwise became ineligible, pursuant to paragraph (j)(1) of this section." In lieu of federal aid, the institution has posted institutional aid on each student account in the amount equal to the student's federal eligibility. The institution has implemented two distinct tracking tools to ensure students are awarded the correct Title IV funding. One tool tracks enrollment changes and is managed by the University Registrar. Any changes made to the tracking tool are automatically communicated by the tool to the Financial Aid Director who reviews to determine if Title IV aid adjustments are required. The second tracking tool monitors the life cycle of the financial aid process for each enrolled student. The tool tracks whether the FAFSA has been received, if there are any FAFSA issues, if the student's aid eligibility can be determined, and if Title IV aid eligibility has been determined and posted to the student record.

Prior Finding References

2019-002

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2020-003
Eligibility
REPEAT OF 2019-003OTHER MATTERS

We tested sixty-three files, forty-seven of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-003. Cause: The condition was caused by oversights in the financial aid office. Effect: The result is students received unsubsidized loans prior to receiving full subsidized loans. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization reclassify $3,083 from unsubsidized to subsidized and increase controls over packaging loans. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2020-003: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Eligibility (E.) Criteria: A first-year student can receive up to $4,500 in subsidized loans and a third-year student can receive up to $5,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested sixty-three files, forty-seven of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-003. Cause: The condition was caused by oversights in the financial aid office. Effect: The result is students received unsubsidized loans prior to receiving full subsidized loans. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization reclassify $3,083 from unsubsidized to subsidized and increase controls over packaging loans. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Per Sec. 668.164(j)(4)(iii), "An institution may not make a late disbursement later than 180 days after the date the institution determines that the student withdrew, as provided in Sec. 668.22, or for a student who did not withdraw, 180 days after the date the student otherwise became ineligible, pursuant to paragraph (j)(1) of this section." In lieu of federal aid, the institution has posted institutional aid on each student account in the amount equal to the student's federal eligibility. The institution has implemented two distinct tracking tools to ensure students are awarded the correct Title IV funding. One tool tracks enrollment changes and is managed by the University Registrar. Any changes made to the tracking tool are automatically communicated by the tool to the Financial Aid Director who reviews to determine if Title IV aid adjustments are required. The second tracking tool monitors the life cycle of the financial aid process for each enrolled student. The tool tracks whether the FAFSA has been received, if there are any FAFSA issues, if the student's aid eligibility can be determined, and if Title IV aid eligibility has been determined and posted to the student record.

Prior Finding References

2019-003

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2020-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2019-007QUESTIONED COSTS

We tested twenty-seven drop students and found three incorrect refund calculations. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Finding 2019-007. Cause: The condition was caused by using an incorrect number of days in Step 2 of the Return to Title IV refund calculations for all three students and by not properly adjusting a Pell grant prior to calculating the refund for one of the students as well. Effect: The result is the Institution retained funds that need to be refunded to the Department of Education. Questioned Costs: $3,500 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization refund $3,500 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2020-004: INCORRECT REFUND CALCULATIONS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twenty-seven drop students and found three incorrect refund calculations. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Finding 2019-007. Cause: The condition was caused by using an incorrect number of days in Step 2 of the Return to Title IV refund calculations for all three students and by not properly adjusting a Pell grant prior to calculating the refund for one of the students as well. Effect: The result is the Institution retained funds that need to be refunded to the Department of Education. Questioned Costs: $3,500 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization refund $3,500 to the Department of Education and increase controls over refund calculations. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

The institution has completed the required R2T4 forms for the four identified students and returned the Title IV aid as indicated on each R2T4 form. The Financial Aid Director communicates with the Executive Vice President before building Academic Calendars within the government system to ensure all breaks are included. The Student Information System is used to identify the start and end date for each Academic Calendar built within the government system. The tracking tool that identifies enrollment changes will remedy the finding regarding Pell grant aid that was not properly adjusted prior to calculating the refund using the R2T4 form.

Prior Finding References

2019-007

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2020-005
Special Tests & Provisions
REPEAT OF 2019-007QUESTIONED COSTSOTHER MATTERS

We tested twenty-seven drop students and noted one late refund and one unpaid refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-007. Cause: The condition was caused by oversights in the financial aid department. Effect: The result is the Institution is retaining monies which need to be returned to the Department of Education. Questioned Costs: $5,300 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization refund $599 to the Department of Education and increase controls over refunds. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2020-005: LATE AND UNPAID REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: Refunds, if necessary, must be calculated and made within 45 calendar days of the date the student withdraws (34 CFR 668.22, 685.306). Condition: We tested twenty-seven drop students and noted one late refund and one unpaid refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-007. Cause: The condition was caused by oversights in the financial aid department. Effect: The result is the Institution is retaining monies which need to be returned to the Department of Education. Questioned Costs: $5,300 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization refund $599 to the Department of Education and increase controls over refunds. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

The institution has completed the required R2T4 forms for the two identified students and returned the Title IV aid as indicated on each R2T4 form. The institution has implemented a distinct tracking tool to ensure the correct adjustments are made to ensure the correct Title IV funding is refunded back to the Department of Education within the required 45 day time period. The tool tracks enrollment changes and is managed by the University Registrar. Any changes made to the tracking tool are automatically communicated by the tool to the Financial Aid Director who reviews to determine if Title IV aid adjustments are required.

Prior Finding References

2019-007

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2020-006
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-008

We tested sixty-three files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for twenty-nine students. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding 2019-008. Cause: The condition was caused by a lack of controls over enrollment status reporting. Effect: The results are students? enrollment dates were reported to NSLDS inaccurately. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization update the students? effective dates in NSLDS and the implement procedures to ensure enrollment statuses are submitted accurately. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2020-006: INACCURATE ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: We tested sixty-three files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for twenty-nine students. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding 2019-008. Cause: The condition was caused by a lack of controls over enrollment status reporting. Effect: The results are students? enrollment dates were reported to NSLDS inaccurately. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization update the students? effective dates in NSLDS and the implement procedures to ensure enrollment statuses are submitted accurately. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

The financial Aid Director is set up to receive notices from the Student Loan Clearinghouse on when to submit enrollment files. In addition, notices are sent regarding errors within each enrollment file. Upon receipt, the Financial Aid Director reviews each student with errors and resolves based on information within the Student Information System and/or through communication with the University Registrar.

Prior Finding References

2019-008

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2020-007
Cash Management
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-009

Throughout the year, Direct Loan School Account Statements were not reconciled to the Federal Funds bank account, G5 and internal records as required. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding 2019-009. Cause: The condition was caused by a lack of controls over Direct Loan School Account Statement reconciliations. Effect: As a result, the Institution could be using ineligible monies. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization implement procedures to reconcile the Direct Loan School Account Statements properly. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2020-007: DIRECT LOAN SCHOOL ACCOUNT STATEMENTS NOT RECONCILED FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Cash Management (C.) Criteria: An institution must reconcile the Direct Loan School Account statement each month to verify all approved monies were drawn down and disbursed (34 CFR 668.24, 688.163). Condition: Throughout the year, Direct Loan School Account Statements were not reconciled to the Federal Funds bank account, G5 and internal records as required. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding 2019-009. Cause: The condition was caused by a lack of controls over Direct Loan School Account Statement reconciliations. Effect: As a result, the Institution could be using ineligible monies. Questioned Costs: $0 Statistical sampling was not used when making sample selections. Recommendation: We recommend the Organization implement procedures to reconcile the Direct Loan School Account Statements properly. Views of Responsible Officials: The Organization agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

The deficiency has been remedied through adjusting internal processes and procedures. The Institution is downloading the School Account Statement (SAS) files and reconciling these files against the institutional loan batch files monthly. In addition, each G5 drawdown is reconciled to the loan batch file. If a variance is found, the Financial Aid office works in coordination with the University Business Office to identify the discrepancy and evaluate the compliant method to remedy the discrepancy which is documented and saved as a part of the monthly reconciliation process.

Prior Finding References

2019-009

About Cash Management →

FY 2019-06-30

$1,277,993 federal awards expended

FAC accepted this audit on April 1, 2020 — management decision was due October 1, 2020.

2019-002
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2018-001QUESTIONED COSTS

We tested forty files and four students received Pell grants in excess of their allowed amount and three students did not receive the full amount of their allowed Pell grants. The students were eligible for $24,731, but received $26,536. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-001. Cause: The condition was caused by a breakdown in controls over packaging Pell grants.Effect: The results is the students received incorrect Pell monies. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $4,159 to the Department of Education, credit $2,354 to the students' account and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-002: INCORRECT PELL GRANTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM CFDA#: 84.063 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student?s Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested forty files and four students received Pell grants in excess of their allowed amount and three students did not receive the full amount of their allowed Pell grants. The students were eligible for $24,731, but received $26,536. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-001. Cause: The condition was caused by a breakdown in controls over packaging Pell grants.Effect: The results is the students received incorrect Pell monies. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $4,159 to the Department of Education, credit $2,354 to the students' account and increase controls over Pell grants. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-002-KCC will refund the excess funds as soon as the DOE instructs them to do so. The DOE requested that KCC not make any refunds until the Program Review was completed.

Prior Finding References

2018-001

About Eligibility →
2019-003
Eligibility
QUESTIONED COSTSOTHER MATTERS

We tested forty files and one student received a loan in excess of subsidized need. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by packaging the loan based on the wrong grade level. Effect: The result is a student received ineligible loan proceeds. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution reclassify $500 from subsidized to unsubsidized and increase controls over packaging loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-003: FEDERAL DIRECT LOAN RECEIVED IN EXCESS OF SUBSIDIZED NEED FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Eligibility (E.) Criteria: A second-year student can receive up to $4,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested forty files and one student received a loan in excess of subsidized need. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by packaging the loan based on the wrong grade level. Effect: The result is a student received ineligible loan proceeds. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution reclassify $500 from subsidized to unsubsidized and increase controls over packaging loans. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-003- KCC will refund the excess subsidized loan as soon as the DOE directs us to do so.

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2019-004
Eligibility
QUESTIONED COSTSOTHER MATTERS

We tested forty files and applications selected for verification did not match supporting documentation for two students and contain supporting documentation for one student. We consider this to be an instance of non-compliance. Cause: The condition was caused by various oversights in the financial aid department. Effect: The result of not properly verifying a student?s Institutional Student Information Report (ISIR) to supporting documentation is the student could be ineligible or could have received an unauthorized award. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution attempt to properly update the verification and if unable to do so, refund $9,930 to the Department of Education. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-004: INCOMPLETE VERIFICATIONS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Eligibility (E.) Criteria: An institution shall require each student whose application is selected for verification to verify all of the applicable items specified (34 CFR 668.54). Condition: We tested forty files and applications selected for verification did not match supporting documentation for two students and contain supporting documentation for one student. We consider this to be an instance of non-compliance. Cause: The condition was caused by various oversights in the financial aid department. Effect: The result of not properly verifying a student?s Institutional Student Information Report (ISIR) to supporting documentation is the student could be ineligible or could have received an unauthorized award. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution attempt to properly update the verification and if unable to do so, refund $9,930 to the Department of Education. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-004- KCC would like to correct the ISIR to determine if any Pell needs to be returned on Students B2 and B4.

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2019-005
Special Tests & Provisions
OTHER MATTERS

We tested forty files and proof of loan exit counseling was missing for two students. We consider this finding to be an instance of non-compliance.Cause: The condition was caused by oversights in the financial aid department. Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution improve controls over exit counseling. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-005: MISSING PROOFS OF LOAN EXIT COUNSELING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Special Tests and Provisions (N.) - Disbursements Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304). Condition: We tested forty files and proof of loan exit counseling was missing for two students. We consider this finding to be an instance of non-compliance.Cause: The condition was caused by oversights in the financial aid department. Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution improve controls over exit counseling. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-005-The KCC FA Director has set time aside weekly to process all withdrawals. The FA Director will use the FA Checklist to assure that all aspects of student withdrawal processing are completed. This will ensure that every student will receive exit counseling.

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2019-006
Special Tests & Provisions
REPEAT OF 2018-003QUESTIONED COSTSOTHER MATTERS

We tested forty files and dates of Title IV disbursements posted to account ledgers did not agree to the dates reported to the Common Origination and Disbursement (COD) System for three students. We consider this finding to be instances of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-003. Cause: The condition was caused by oversights in the financial aid department.Effect: The result is incorrect disbursement dates were reported to the Department of Education. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution correct the disbursement dates in COD and tighten controls over reporting disbursements dates. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-006: INACCURATE REPORTING OF DISBURSEMENT DATES TO COMMON ORIGINATION AND DISBURSEMENT (COD) SYSTEM FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Special Tests and Provisions (N.) - Disbursements Criteria: The disbursement amounts and dates reported to the Department of Education must be the amounts and dates of the actual disbursement to the students? accounts (CFR 34 668.164). Condition: We tested forty files and dates of Title IV disbursements posted to account ledgers did not agree to the dates reported to the Common Origination and Disbursement (COD) System for three students. We consider this finding to be instances of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-003. Cause: The condition was caused by oversights in the financial aid department.Effect: The result is incorrect disbursement dates were reported to the Department of Education. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution correct the disbursement dates in COD and tighten controls over reporting disbursements dates. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-006-An attempt was made to correct these items, but was not able to due to the AY being closed. KCC will correct the dates if an extension is granted after the Program Review is finalized

Prior Finding References

2018-003

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2019-007
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2018-004, 2018-005QUESTIONED COSTS

We tested twenty drop students in our sample and noted three unpaid refunds, two of which were also incorrect refund calculations as well. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Findings UG2018-004 and UG2018-005. Cause: The condition was caused by using an incorrect amount in Step 1 of the Return to Title IV refund calculation for one student, using an incorrect number of days in Step 2 of the Return to Title IV refund calculation for another student and by not paying refunds calculated for all three students. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $1,971 to the Department of Education and increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-007: INCORRECT AND UNPAID REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Further, the Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twenty drop students in our sample and noted three unpaid refunds, two of which were also incorrect refund calculations as well. We consider this finding to be a significant deficiency and is a repeat finding shown in Section IV of this report as prior year Findings UG2018-004 and UG2018-005. Cause: The condition was caused by using an incorrect amount in Step 1 of the Return to Title IV refund calculation for one student, using an incorrect number of days in Step 2 of the Return to Title IV refund calculation for another student and by not paying refunds calculated for all three students. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution refund $1,971 to the Department of Education and increase controls over refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-007- KCC was asked by the DOE to not make any refunds until the conclusion of the Program Review. The Program Review has not yet concluded. KCC will refund the funds when the DOE directs them to do so.

Prior Finding References

2018-004, 2018-005

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2019-008
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-006

We tested forty files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for twenty-nine students. We also noted that enrollment update responses were not submitted timely for March 2019. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-006. Cause: The condition was caused by a lack of controls over enrollment status reporting. Effect: The results are students? enrollment dates were reported to NSLDS inaccurately and untimely. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution update the students? effective dates in NSLDS and the implement procedures to ensure enrollment statuses are submitted timely and accurately. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-008: INACCURATE AND UNTIMELY ENROLLMENT STATUS REPORTING FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.063 & 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Reporting (L.) Criteria: Institutions are required to provide enrollment update responses to the Enrollment Reporting Roster File within fifteen days of receipt (34 CFR 685.309). Condition: We tested forty files and enrollment status effective dates were either incorrectly reported or not reported to the National Student Loan Data System (NSLDS) for twenty-nine students. We also noted that enrollment update responses were not submitted timely for March 2019. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-006. Cause: The condition was caused by a lack of controls over enrollment status reporting. Effect: The results are students? enrollment dates were reported to NSLDS inaccurately and untimely. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution update the students? effective dates in NSLDS and the implement procedures to ensure enrollment statuses are submitted timely and accurately. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-008- An attempt was made to correct all reporting but the FA Director was unable to correct some. The FA Director will contact NSLDS requesting assistance with updating the remaining student information.

Prior Finding References

2018-006

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2019-009
Cash Management
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-007

Throughout the year, Direct Loan School Account Statements were not reconciled to the Federal Funds bank account as required. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-007. Cause: The condition was caused by a lack of controls over Direct Loan School Account Statement reconciliations.Effect: As a result, the Institution could be using ineligible monies. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution implement procedures to reconcile the Direct Loan School Account Statements properly. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-009: DIRECT LOAN SCHOOL ACCOUNT STATEMENTS NOT RECONCILED FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2018-2019 Compliance Requirement: Cash Management (C.) Criteria: An institution must reconcile the Direct Loan School Account statement each month to verify all approved monies were drawn down and disbursed (34 CFR 668.24, 688.163). Condition: Throughout the year, Direct Loan School Account Statements were not reconciled to the Federal Funds bank account as required. We consider this finding to be a material weakness and is a repeat finding shown in Section IV of this report as prior year Finding UG2018-007. Cause: The condition was caused by a lack of controls over Direct Loan School Account Statement reconciliations.Effect: As a result, the Institution could be using ineligible monies. See Schedule of Findings and Questioned Costs for chart/table Statistical sampling was not used when making sample selections. Recommendation: We recommend the Institution implement procedures to reconcile the Direct Loan School Account Statements properly. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Finding 2019-009- KCC Did not have a written procedure for Monthly Reconciliation. KCC has attached the new written procedure. Title IV Monthly Reconciliation Procedure The business office and the financial aid office work closely on a daily basis to ensure that all fund drawdowns are accurate. KCC Utilizes the following procedure to further ensure accuracy: Internal Reconciliation The FA Director will compare student ledgers with COD Data weekly on Fridays. At that time, any date or amount adjustments will be made. In addition to communication between the business office and the financial aid office whenever a Title IV drawdown occurs, the Director of Operations, or whoever is in charge of G5, will run a monthly activity report no later than the 10th day of every month to use for comparison to the Federal Bank Statements, Student Ledgers, and Populi. External Reconciliation After the internal accounts have been reconciled, the FA Director will compare the reconciled information with the information in COD and make any necessary date or disbursement adjustments. Recordkeeping Any documentation related to the reconciliation of Title IV accounts will be kept in a binder, according to Academic Year, in the Financial Aid Office.

Prior Finding References

2018-007

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