EIN: 570439615
UEI: Z1JEZBEACEK9
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 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 July 30, 2026 (28 days ago).
What is a management decision? →In a sample of twenty-five (25) students, systematically selected, subject to Return of Title IV (R2T4) requirements, we identified 6 instances where the R2T4 calculation was performed incorrectly. Specifically: • Three (3) instances involved using an incorrect total number of calendar days in the period of enrollment or payment period. • Two (2) instances involved using the incorrect Pell grant disbursed amount in the calculation. • One (1) instance involved using an incorrect withdrawal date/last date of attendance. The institution provided supporting documentation as evidence that corrections were made prior to the issuance of our report. The findings revealed a material weakness over compliance related to R2T4 requirements. Based on the number of findings, and inquiry and management assertion, we determined that the findings were pervasive to the R2T4 population and it was determined that expanding that sample would not be necessary. Management reviewed the entirety of the population and reperformed the R2T4 calculations, as appropriate. Supporting documentation was provided. Cause: The staff member previously responsible for performing R2T4 calculations retired, and the responsibility was assigned to a new employee with limited knowledge of the applicable regulations. A review process was not in place to ensure the accuracy of the calculations, which resulted in errors not being identified until they were brought to management’s attention by the auditors. Effect: As a result of the errors identified in the R2T4 calculations, the institution did not accurately determine the amount of Title IV funds earned and unearned for the affected students. The known questioned cost associated with these errors total $1,807 representing amounts of overpayment to students. Additionally, due to incorrect calculations there were underpayments to students in the amount of $1,694. Recommendation to prevent future occurrences of the deficiency identified. We recommend that the institution strengthen its controls over the R2T4 calculation process by: 1. Providing comprehensive training to staff responsible for performing R2T4 calculations to ensure understanding of regulatory requirements. 2. Implementing a formal review process whereby a second qualified individual reviews and approves all R2T4 calculations before finalization. 3. Establishing written procedures and checklists to ensure the correct number of calendar days, Pell Grant disbursement amounts, and withdrawal dates are consistently and accurately applied. 4. Periodically monitoring compliance with these procedures to identify and correct errors in a timely manner.
Show full finding ▾Hide full finding ▴DEPARTMENT OF EDUCATION- Student Financial Aid Cluster MATERIAL WEAKNESS (MW) FINDING 2025-001: Special Tests and Provisions – Return to Title IV Funds Criteria: Federal regulation 34 CFR § 668.22 states that when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date. Specific requirements include: • Calendar Days: Per 34 CFR § 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. • Calculation of the amount of title IV assistance earned by the student: Per 34 CFR § 668.22(e)(4), the unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. • Withdrawal Date/Last Date of Attendance: Per 34 CFR § 668.22(c) and (l)(3)(i), the withdrawal date must be determined in accordance with the type of withdrawal and must reflect the student’s actual last date of attendance at an academically related activity, as documented by the institution. Condition: In a sample of twenty-five (25) students, systematically selected, subject to Return of Title IV (R2T4) requirements, we identified 6 instances where the R2T4 calculation was performed incorrectly. Specifically: • Three (3) instances involved using an incorrect total number of calendar days in the period of enrollment or payment period. • Two (2) instances involved using the incorrect Pell grant disbursed amount in the calculation. • One (1) instance involved using an incorrect withdrawal date/last date of attendance. The institution provided supporting documentation as evidence that corrections were made prior to the issuance of our report. The findings revealed a material weakness over compliance related to R2T4 requirements. Based on the number of findings, and inquiry and management assertion, we determined that the findings were pervasive to the R2T4 population and it was determined that expanding that sample would not be necessary. Management reviewed the entirety of the population and reperformed the R2T4 calculations, as appropriate. Supporting documentation was provided. Cause: The staff member previously responsible for performing R2T4 calculations retired, and the responsibility was assigned to a new employee with limited knowledge of the applicable regulations. A review process was not in place to ensure the accuracy of the calculations, which resulted in errors not being identified until they were brought to management’s attention by the auditors. Effect: As a result of the errors identified in the R2T4 calculations, the institution did not accurately determine the amount of Title IV funds earned and unearned for the affected students. The known questioned cost associated with these errors total $1,807 representing amounts of overpayment to students. Additionally, due to incorrect calculations there were underpayments to students in the amount of $1,694. Recommendation to prevent future occurrences of the deficiency identified. We recommend that the institution strengthen its controls over the R2T4 calculation process by: 1. Providing comprehensive training to staff responsible for performing R2T4 calculations to ensure understanding of regulatory requirements. 2. Implementing a formal review process whereby a second qualified individual reviews and approves all R2T4 calculations before finalization. 3. Establishing written procedures and checklists to ensure the correct number of calendar days, Pell Grant disbursement amounts, and withdrawal dates are consistently and accurately applied. 4. Periodically monitoring compliance with these procedures to identify and correct errors in a timely manner.
MW 2025-001 SFA Cluster: R2T4 Corrective Action Plan Contact Person: Jeff Boyle, Director of Financial Corrective Action Plan: 1. Have at least two staff members enroll and complete the R2T4 training module conducted by NASFAA. Tonja Suttles and Melissa Satterwhite completed the course and passed the credential exam. Suzanne Bonner sat in on a few of the sessions. 2. Make changes to the R2T4 spreadsheet. a. Maintain a separate tab for each calculation group to make tracking and internal reviews easier. Process has been completed and started being used during the 2025 fall semester. b. Add additional columns to the spreadsheet that will provide the necessary data to perform the R2T4 calculation within Colleague and act as a check and balance as the calculation is being performed. There are several columns with calculated data or data coming from a source outside of Colleague. These data values can then be compared to the values Colleague calculates and the two should match. Columns have been added and began being used with the 2025 fall semester. 3. It will be established that one staff member will do the R2T4 calculation and a second staff member will do a spot check of a spot check to ensure the calculation was done properly using the correct data. The number of students checked will depend on the number of students within the calculation groups. The number of students in a group can range from 2 to several hundred. This process was put into practice starting with the 09/17/25 calculation group. Jeff Boyle, Director of Financial Aid, performed all the R2T4 calculations for the 2025 fall term and Tonja Suttles, Assistant Director of Financial Aid, performed 100% review of all the calculations. This will change once we are assured this process is working the way we expect it. 4. The external spreadsheets and charts used for the R2T4 calculation contain a tremendous amount of data elements and are created two years in advance of being used. A process will be established where various staff members within the office will review the data prior to our using it for the R2T4 calculation. This has been implemented as of the 2025 fall semester. All the 2025-2026 terms have been reviewed. A secondary review will be done on each term just prior to the data being used for that term’s R2T4 calculations. The data will be reviewed again at any point we determine the data may not be correct.
In a sample of twenty-five (25) title IV outstanding checks, systematically selected, we found five instances where uncashed title IV checks were not returned to the Department of Education within 240 days from the issuance of the check. The institution provided supporting documentation as evidence that the required funds were sent back to the Department of Education through the G5 system prior to the issuance of our report. Management reviewed the entirety of the population and all uncashed title IV checks were refunded through the G5 system. Supporting documentation was provided. Cause: The process of evaluating outstanding checks was not performed in a timely fashion. This process should have been done at least quarterly. With staff turnover and new position appointments, this process was omitted. It was on the radar of the Business Office staff, but time did not permit the completion of this process. Effect: The institution did not return uncashed title IV checks timely to the Department of Education as required. Recommendation to prevent future occurrences of the deficiency identified: The institution should strengthen its controls over the monitoring and timely return of unclaimed Title IV credit balance checks to ensure compliance with 34 CFR §668.164(l). Specifically, management should implement and document procedures to: 1. Track all Title IV disbursements issued by check, including the issuance date and applicable return deadlines. 2. Perform periodic (at least monthly) reviews of outstanding Title IV checks to identify uncashed items approaching the 240-day return requirement. 3. Ensure uncashed Title IV checks are returned to the U.S. Department of Education within 240 days of issuance when checks are not cashed or otherwise negotiated. 4. Assign clear responsibility for monitoring outstanding checks and returning funds and provide training to staff involved in Title IV disbursement and reconciliation processes. 5. Retain documentation evidencing timely monitoring, review, and return of Title IV funds to support compliance and audit review. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan
Show full finding ▾Hide full finding ▴DEPARTMENT OF EDUCATION- Student Financial Aid Cluster COMPLIANCE FINDING 2025-002 Special Tests and Provisions – Disbursements to or on behalf of Students Criteria: Federal regulation 34 CFR §668.164(l) states: (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, HEA program funds, except FWS program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition: In a sample of twenty-five (25) title IV outstanding checks, systematically selected, we found five instances where uncashed title IV checks were not returned to the Department of Education within 240 days from the issuance of the check. The institution provided supporting documentation as evidence that the required funds were sent back to the Department of Education through the G5 system prior to the issuance of our report. Management reviewed the entirety of the population and all uncashed title IV checks were refunded through the G5 system. Supporting documentation was provided. Cause: The process of evaluating outstanding checks was not performed in a timely fashion. This process should have been done at least quarterly. With staff turnover and new position appointments, this process was omitted. It was on the radar of the Business Office staff, but time did not permit the completion of this process. Effect: The institution did not return uncashed title IV checks timely to the Department of Education as required. Recommendation to prevent future occurrences of the deficiency identified: The institution should strengthen its controls over the monitoring and timely return of unclaimed Title IV credit balance checks to ensure compliance with 34 CFR §668.164(l). Specifically, management should implement and document procedures to: 1. Track all Title IV disbursements issued by check, including the issuance date and applicable return deadlines. 2. Perform periodic (at least monthly) reviews of outstanding Title IV checks to identify uncashed items approaching the 240-day return requirement. 3. Ensure uncashed Title IV checks are returned to the U.S. Department of Education within 240 days of issuance when checks are not cashed or otherwise negotiated. 4. Assign clear responsibility for monitoring outstanding checks and returning funds and provide training to staff involved in Title IV disbursement and reconciliation processes. 5. Retain documentation evidencing timely monitoring, review, and return of Title IV funds to support compliance and audit review. Views of Responsible Officials and Planned Corrective Actions – See Corrective Action Plan
COMPLIANCE FINDING 2025-002 SFA Cluster: Disbursement to or on Behalf of Students Contact Person: Missy Hughes, Director of Finance Corrective Action Plan: The Business Office is currently seeking an AP/Payroll Manager who will supervise the outstanding check process. The process will be performed and maintained by the Financial Coordinator, Kyle Burnett. 1. Track all Title IV disbursements issued by check, including the issuance date and applicable return deadlines. During monthly bank and check reconciliations, any outstanding check related to Title IV funds will be reviewed by Kyle Burnett, Financial Coordinator. 2. Perform periodic (at least monthly) reviews of outstanding Title IV checks to identify uncashed items approaching the 240-day return requirement. The process of reviewing outstanding Title IV checks will be performed and maintained by the Financial Coordinator, Kyle Burnett. Kyle will review the outstanding checks related to student refunds monthly. 3. Ensure uncashed Title IV checks are returned to the U.S. Department of Education within 240 days of issuance when checks are not cashed or otherwise negotiated. Kyle Burnett, Financial Coordinator, will work with Linda Briggs, Student Account Coordinator and Financial Aid to be sure Title IV checks are returned to the U.S. Department of Education within 240 days of issuance, if still outstanding. 4. Assign clear responsibility for monitoring outstanding checks and returning funds and provide training to staff involved in Title IV disbursement and reconciliation processes. Kyle Burnett, Financial Coordinator, will be trained in Title IV disbursement and reconciliation processes and will work with the Accounts Receivable staff as well as Financial Aid to determine appropriate actions regarding the stale dated check items. 5. Retain documentation evidencing timely monitoring, review, and return of Title IV funds to support compliance and audit review. A SharePoint has been established that is currently maintained by Linda Briggs, Student Account Coordinator and Jeremy Elam, Controller. Kyle Burnett, Financial Coordinator, will be added to this SharePoint. This will be monitored and updated regarding check statuses related to Title IV funds.
FAC accepted this audit on May 23, 2022 — management decision was due November 23, 2022.
There is a lack of evidence that the College performed all of the required monthly Direct Loan reconciliation. Cause: The COVID-19 pandemic presented many problems with financial aid staff being out of the office for significant amounts of time due to exposure including family members being exposed. The Financial Aid Office lost a staff member a year and a half ago to retirement and the position has yet to be filled. Due to staff shortage management used their available resources for the most critical duties in order to continue serving the students. Effect: The College is not in compliance with the Direct Loan program participation agreement. Questioned Cost: None Identification of a Repeat Finding: Not a repeat finding. Recommendation: We recommend the College perform the required monthly Direct Loan reconciliation. Views of Responsible Officials: The Financial Aid Office (FAO) agrees with this conclusion. The FAO was aware of the deficiency, but due to the added workload resulting from various COVID-19 related issues, a staff position that has remained vacant for over 18 months, and the implantation of a new college initiative, the office was unable to meet the requirement. Direct Loan reconciliation is on the office calendar as a monthly process, but once missed there was no retroactive action that could be taken to correct the deficiency. The Direct Loan reconciliation process remains on the calendar and extra effort will be taken in the 2021-2022 award year to ensure the process is completed monthly.
Show full finding ▾Hide full finding ▴2021-001 - Special Test and Provision- Borrower Data and Reconciliation (Direct Loan) Federal Agency: Department of Education Program: Student Financial Aid Cluster Criteria: On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. (34 CFR 685.300(b)(5)) Condition: There is a lack of evidence that the College performed all of the required monthly Direct Loan reconciliation. Cause: The COVID-19 pandemic presented many problems with financial aid staff being out of the office for significant amounts of time due to exposure including family members being exposed. The Financial Aid Office lost a staff member a year and a half ago to retirement and the position has yet to be filled. Due to staff shortage management used their available resources for the most critical duties in order to continue serving the students. Effect: The College is not in compliance with the Direct Loan program participation agreement. Questioned Cost: None Identification of a Repeat Finding: Not a repeat finding. Recommendation: We recommend the College perform the required monthly Direct Loan reconciliation. Views of Responsible Officials: The Financial Aid Office (FAO) agrees with this conclusion. The FAO was aware of the deficiency, but due to the added workload resulting from various COVID-19 related issues, a staff position that has remained vacant for over 18 months, and the implantation of a new college initiative, the office was unable to meet the requirement. Direct Loan reconciliation is on the office calendar as a monthly process, but once missed there was no retroactive action that could be taken to correct the deficiency. The Direct Loan reconciliation process remains on the calendar and extra effort will be taken in the 2021-2022 award year to ensure the process is completed monthly.
The Financial Aid Office (FAO) agrees with this conclusion. The FAO was aware of the deficiency, but due to the added workload resulting from various COVID-19 related issues, a staff position that has remained vacant for over 18 months, and the implantation of a new college initiative, the office was unable to meet the requirement. Direct Loan reconciliation is on the office calendar as a monthly process, but once missed there was no retroactive action that could be taken to correct the deficiency. The Direct Loan reconciliation process remains on the calendar and extra effort will be taken in the 2021-2022 award year to ensure the process is completed monthly.
For the HEERF II student portion, the required quarterly public reporting was not conspicuously posted on the College primary website. Cause: The COVID-19 pandemic presented many problems with financial aid staff being out of the office for significant amounts of time due to exposure including family members being exposed. The Financial Aid Office lost a staff member a year and a half ago to retirement and the position has yet to be filled. Due to staff shortage management used their available resources for the most critical duties in order to continue serving the students. Effect: The College is not in compliance with the CRRSAA quarterly public reporting requirement. Questioned Cost: None Identification of a Repeat Finding: Not a repeat finding. Recommendation: We recommend the College publicly post the quarterly reporting with in the required timeframe. Views of Responsible Officials: The Financial Aid Office (FAO) agrees with this conclusion and corrected the issue as soon as was identified. The HEERF II reports were created but were not loaded to the website. The reports have since been loaded the financial aid website and will be loaded to the college?s COVID-19 page as soon possible.
Show full finding ▾Hide full finding ▴2021-002 - Reporting- Special Reporting Federal Agency: Department of Education Program: Coronavirus Response and Relief Supplemental Appropriation Act (CRRSAA) - HEERF II, Student Portion- CFDA #84.425E Criteria: The Certification and Agreements for the CRRSAA and ARP (a)(1) and (a)(4) funds provide that each institution applying for HEERF funds must promptly and timely provide a detailed accounting of the use and expenditure of the funds in such manner and with such frequency as the Secretary may require. Each HEERF participating institution must post the information listed below on the institution?s primary website, as an initial report under the CRRSAA and ARP (a)(1) and (a)(4) programs. This report is associated with the approved information collection under OMB control number 1801? 0005. The Department encourages institutions to report as soon as possible, but no later than 30 days after the publication of this notice or 30 days after the date the Department first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. (CRRSAA section 314(e)) Condition: For the HEERF II student portion, the required quarterly public reporting was not conspicuously posted on the College primary website. Cause: The COVID-19 pandemic presented many problems with financial aid staff being out of the office for significant amounts of time due to exposure including family members being exposed. The Financial Aid Office lost a staff member a year and a half ago to retirement and the position has yet to be filled. Due to staff shortage management used their available resources for the most critical duties in order to continue serving the students. Effect: The College is not in compliance with the CRRSAA quarterly public reporting requirement. Questioned Cost: None Identification of a Repeat Finding: Not a repeat finding. Recommendation: We recommend the College publicly post the quarterly reporting with in the required timeframe. Views of Responsible Officials: The Financial Aid Office (FAO) agrees with this conclusion and corrected the issue as soon as was identified. The HEERF II reports were created but were not loaded to the website. The reports have since been loaded the financial aid website and will be loaded to the college?s COVID-19 page as soon possible.
The Financial Aid Office (FAO) agrees with this conclusion and corrected the issue as soon as was identified. The HEERF II reports were created but were not loaded to the website. The reports have since been loaded the financial aid website and will be loaded to the college?s COVID-19 page as soon possible.
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