EIN: 591157081
UEI: PCWMNA2JK646
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 9, 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 9, 2026 (48 days ago).
What is a management decision? →During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 10 Students had one or more noncompliant reporting elements noted below. - 2 Instances where a students campus-level and program level enrollment effective date did not match the institutions records. - 9 Instances where students campus level enrollment was not certified every 60 days to NSLDS during active enrollment period. - 3 Instances in which Program Level Program Begin Date per the NSLDS Program Enrollment Detail did not agree to institutional records. Questioned costs Known: None. Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 10 students with exceptions. 4 students had multiple instances of noncompliance. Cause: Turnover within the registrar department and lack of structured review and approval process. Effect: The NSLDS system is not updated with the student information in time which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2023-001. Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information with separate record types;"Campus Level" and "Program Level,"both of which need to be reported accurately and timely. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Additionally, the College is required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 10 Students had one or more noncompliant reporting elements noted below. - 2 Instances where a students campus-level and program level enrollment effective date did not match the institutions records. - 9 Instances where students campus level enrollment was not certified every 60 days to NSLDS during active enrollment period. - 3 Instances in which Program Level Program Begin Date per the NSLDS Program Enrollment Detail did not agree to institutional records. Questioned costs Known: None. Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 10 students with exceptions. 4 students had multiple instances of noncompliance. Cause: Turnover within the registrar department and lack of structured review and approval process. Effect: The NSLDS system is not updated with the student information in time which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2023-001. Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Department of Education Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Office of the Registrar has added a Systems Analyst position, who is now responsible for Clearinghouse submissions, including enrollment reporting and monitoring and resolving errors. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions with support from our software provider Jenzabar, the National Student Clearinghouse, and the College’s Information Technology Department and Advising Office to ensure that enrollment reporting and error resolution is accurate and timely. Recommended changes to the enrollment reporting were adopted and added to the written procedures. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielson (Registrar Systems Analyst), Nicholas Jobe (Registrar), and Sheia Pleasant (Financial Aid Director). Planned completion date for corrective action plan: Completed December 31, 2024
2023-001
FAC accepted this audit on March 20, 2024 — management decision was due September 20, 2024.
During our testing of the Direct Loan and Pell Grant programs, we selected 24 enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 3 of 24 enrollment changes tested did not have the correctly reported Program Begin Date within the current program level reporting. Questioned costs Known: None. Context: Out of our sample of 24 students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we noted 3 whom exhibited one instance of noncompliance in the student’s NSLDS Program-Level enrollment data elements that the Department of Education considers high risk. Cause: Lack of appropriate policy and procedure coupled with multiple transitions within the registrar department led to enrollment reporting deficiencies. Effect: The NSLDS system is potentially not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat Finding: No. Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information with separate record types; “Campus Level” and “Program Level,” both of which need to be reported accurately and timely. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected 24 enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 3 of 24 enrollment changes tested did not have the correctly reported Program Begin Date within the current program level reporting. Questioned costs Known: None. Context: Out of our sample of 24 students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we noted 3 whom exhibited one instance of noncompliance in the student’s NSLDS Program-Level enrollment data elements that the Department of Education considers high risk. Cause: Lack of appropriate policy and procedure coupled with multiple transitions within the registrar department led to enrollment reporting deficiencies. Effect: The NSLDS system is potentially not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat Finding: No. Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Student Financial Aid Cluster – Special Tests and Provisions – NSLDS Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment to NSLDS using the National Student Clearinghouse (NSC). The Registrar’s Office will collaborate with our Information Technology Department to identify and correct all students with erroneous program start dates. As recommended by CLA, the Registrar’s Office is reviewing its process for Clearinghouse submissions in collaboration with the Information Technology Department and Advising Office to ensure that the program-level enrollment effective dates are accurately reflected when a student submits a change of major. Names of the contact persons responsible for corrective action: Sheia Pleasant-Doine and Adam Doine Planned completion date for corrective action plan: May 3, 2024
CLA identified that the college fails to meet one of the compliance requirements outlined in the GLBA Safeguards Rule within 16 CFR 314. Questioned costs Known: None. Context: During our testing, we noted the College failed to meet one of the compliance requirements outlined in the GLBA Safeguards Rule. The College has been continuously drafting and implementing policies as part of their written information security program, however as of June 30, 2023, one requirement was not met. Cause: The College is currently drafting the necessary policy which was not formally in place. Effect: Failure to have a complete written information security program in place causes the College to not be GLBA compliant and potentially put institutional and student data at risk. Repeat Finding: No. Recommendation: We recommend the College finalize its written information security program to ensure its compliant with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.007 – Supplemental Educational Opportunity Grant 84.033 – College Work study Program 84.379 – Teacher Education Assistance for College and Higher Education Grant 84.038 – Federal Perkins Loans Program Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). ED provides additional information about cybersecurity requirements at https://studentprivacy.ed.gov/security. ED also issued an Electronic Announcement on GLBA compliance that can be found at https://fsapartners.ed.gov/knowledge-center/library/electronicannouncements/2023-02-09/updates-gramm-leach-bliley-act-cybersecurity-requirements. Condition: CLA identified that the college fails to meet one of the compliance requirements outlined in the GLBA Safeguards Rule within 16 CFR 314. Questioned costs Known: None. Context: During our testing, we noted the College failed to meet one of the compliance requirements outlined in the GLBA Safeguards Rule. The College has been continuously drafting and implementing policies as part of their written information security program, however as of June 30, 2023, one requirement was not met. Cause: The College is currently drafting the necessary policy which was not formally in place. Effect: Failure to have a complete written information security program in place causes the College to not be GLBA compliant and potentially put institutional and student data at risk. Repeat Finding: No. Recommendation: We recommend the College finalize its written information security program to ensure its compliant with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Student Financial Aid Cluster – Special Tests and Provisions – GLBA Recommendation: We recommend the College finalize its written information security program to ensure its compliance with the GLBA Safeguards Rule along with appropriately managing its information technology and cybersecurity risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College’s Information Technology department will amend the written program and policy to include all necessary aspects of GLBA compliance and IT management and cybersecurity risk. Names of the contact person responsible for corrective action: Gwen Pechan Planned completion date for corrective action plan: March 31, 2024
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
During our testing of institutional disbursements for the College, we noted that all the institutional funding was allocated to lost revenue, and none was allocated to the earmarking requirement noted above. Questioned costs known: Unknown. Context: During our testing, we noted that the College was not in compliance with the ARP Earmarking requirements. Cause: The policies and procedures of the College did not ensure that grant earmarking requirements were accurately met. Effect: Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the earmarking requirement. Repeat Finding: No. Recommendation: We recommend that the College monitor the earmarking requirements of all grants, to ensure they stay in compliance. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Education Stabilization Fund Assistance Listing Numbers: 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Period: July 1, 2021, to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC ? 1087tt). Condition: During our testing of institutional disbursements for the College, we noted that all the institutional funding was allocated to lost revenue, and none was allocated to the earmarking requirement noted above. Questioned costs known: Unknown. Context: During our testing, we noted that the College was not in compliance with the ARP Earmarking requirements. Cause: The policies and procedures of the College did not ensure that grant earmarking requirements were accurately met. Effect: Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the earmarking requirement. Repeat Finding: No. Recommendation: We recommend that the College monitor the earmarking requirements of all grants, to ensure they stay in compliance. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
2022-001 Educational Stabilization Fund ? Earmarking ? HEERF earmarking requirements. Recommendation: We recommend that the College monitor the earmarking requirements of all grants, to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was caused by improper reporting of items earmarked per requirements. Accounting personnel will review grant/award contracts and associated standards in order to create necessary tracking documents to be submitted to individual responsible for grant/award reporting. Flagler is in the process of hiring a dedicated Grants & Compliance Manager that will be responsible for organizing and tracking requirements moving forward. Name(s) of the contact person(s) responsible for corrective action: Stacey Matthews and Tiffany Moore Planned completion date for corrective action plan: March 23, 2023 reporting on earmarking correction; implementation upon next award
During our testing of HEERF reporting requirements at Flagler College, we noted: 1) Non-Compliant Institutional Reporting a. One of the two institutional reports selected for testing was not posted on the College?s website. 2) Non-Compliant Annual Reporting a. Total institutional expenditures in the annual report did not agree to supporting documentation. 3) Internal Control a. The review and approval control could not be traced to supporting records during testing for any report submitted. Questioned costs known: None. Context: There were 3 separate reporting requirements tested as part of the HEERF Program. Each of the reports had a unique number tested for both internal control and compliance. 1) Public reporting on the (a)(1) Student Aid Portion. a. Both reports tested (two of two) were noncompliant for internal control purposes. 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable. a. One of the reports tested was noncompliant for compliance requirements. b. Both reports tested (Two of two) were noncompliant for internal control purpose. 3) The Annual Report a. The one report tested was noncompliant for compliance and internal control purpose. Cause: The policies and procedures of the College did not ensure that grant reporting requirements were timely and accurately met. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Educational Stabilization Fund Assistance Listing Numbers: 84.425E ? Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Period: July 1, 2021, to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our testing of HEERF reporting requirements at Flagler College, we noted: 1) Non-Compliant Institutional Reporting a. One of the two institutional reports selected for testing was not posted on the College?s website. 2) Non-Compliant Annual Reporting a. Total institutional expenditures in the annual report did not agree to supporting documentation. 3) Internal Control a. The review and approval control could not be traced to supporting records during testing for any report submitted. Questioned costs known: None. Context: There were 3 separate reporting requirements tested as part of the HEERF Program. Each of the reports had a unique number tested for both internal control and compliance. 1) Public reporting on the (a)(1) Student Aid Portion. a. Both reports tested (two of two) were noncompliant for internal control purposes. 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable. a. One of the reports tested was noncompliant for compliance requirements. b. Both reports tested (Two of two) were noncompliant for internal control purpose. 3) The Annual Report a. The one report tested was noncompliant for compliance and internal control purpose. Cause: The policies and procedures of the College did not ensure that grant reporting requirements were timely and accurately met. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
2022-002 Educational Stabilization Fund ? Reporting ? HEERF reporting requirements. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Flagler is in the process of hiring a dedicated Grants & Compliance Manager that will be responsible for organizing and submitting reporting requirements moving forward. In the meantime, preparing of reporting will be completed, reviewed and published by current accounting personnel based on a reporting schedule created upon review of the award documents and related standards. Name(s) of the contact person(s) responsible for corrective action: Stacey Matthews and Tiffany Moore Planned completion date for corrective action plan: March 23, 2023
2021-002
FAC accepted this audit on September 28, 2022 — management decision was due March 28, 2023.
During our testing of the Direct Loan and Pell Grant programs, we selected 40 enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 31 of 40 enrollment changes tested had one or more instances of noncompliance noted below: I. 1 instance where the campus level enrollment effective date was not reported accurately. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. 3 instances where a student?s program enrollment effective date was not reported accurately. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) III. 1 instance where a student?s program enrollment status was not reported accurately. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) IV. 26 instances where the program begin date per the NSLDS program enrollment detail does not agree to college records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) V. 18 instances where the student campus level enrollments were not certified every 60 days. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned costs Known: None. Context: Out of our sample of 40 students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we noted 31 whom exhibited one or more instances of noncompliance in the student?s NSLDS Campus-Level and/or Program-Level enrollment data elements that the Department of Education considers high risk. Cause: Current policies and procedures coupled with multiple transitions within the registrar department led to enrollment reporting deficiencies. Effect: The NSLDS system is potentially not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat Finding: Yes, 2020-001 Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2020, to June 30, 2021 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information with separate record types; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and timely. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected 40 enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 31 of 40 enrollment changes tested had one or more instances of noncompliance noted below: I. 1 instance where the campus level enrollment effective date was not reported accurately. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. 3 instances where a student?s program enrollment effective date was not reported accurately. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) III. 1 instance where a student?s program enrollment status was not reported accurately. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) IV. 26 instances where the program begin date per the NSLDS program enrollment detail does not agree to college records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) V. 18 instances where the student campus level enrollments were not certified every 60 days. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned costs Known: None. Context: Out of our sample of 40 students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we noted 31 whom exhibited one or more instances of noncompliance in the student?s NSLDS Campus-Level and/or Program-Level enrollment data elements that the Department of Education considers high risk. Cause: Current policies and procedures coupled with multiple transitions within the registrar department led to enrollment reporting deficiencies. Effect: The NSLDS system is potentially not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat Finding: Yes, 2020-001 Recommendation: We recommend that the College continue to enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar reports enrollment using the National Student Clearinghouse (NSC). As recommended by CLA, the College has reviewed its process for Clearinghouse submissions in collaboration with a representative from both Jenzabar and the National Student Clearinghouse. Recommended changes to the enrollment reporting were adopted and added to the written procedures. The Office of the Registrar reviews, edits, and corrects the error files. To ensure that timely error resolutions haven been completed, the Office of the Registrar and the Financial Aid Office will work collaboratively once NSC files have been submitted to identify any discrepancies on the NSLDS Enrollment Reporting Summary Report. The Office of Financial Aid and the Office of the Registrar will be reviewing the error reports to ensure that all of the error records are corrected and resubmitted timely and accurately. Name(s) of the contact person(s) responsible for corrective action: Sheia Pleasant-Doine and Adam Doine Planned completion date for corrective action plan: December 1, 2022
2020-001
During our testing of HEERF reporting requirements at Flagler College, we noted: 1) Non-Compliant Student Reporting a. Of the two student reports selected for testing, we were unable to determine that the reports were posted in the timeframe prescribed by the Department. 2) Non-Compliant Institutional Reporting a. One of the two institutional reports selected for testing was not posted on the College?s website. b. Two of the two institutional reports selected for testing did not agree to supporting documentation. 3) Non-Compliant Annual Reporting a. Total student expenditures in the annual report did not agree to supporting documentation. 4) Internal Control a. The review and approval control could not be traced to supporting records during testing for any report submitted. Questioned costs known: None. Context: There were 3 separate reporting requirements tested as part of the HEERF Program. Each of the reports had a unique number tested for both internal control and compliance. 1) Public reporting on the (a)(1) Student Aid Portion. a. One of the two reports tested were noncompliant for compliance purposes. b. Both reports tested (two of two) were noncompliant for internal control purposes. 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable. a. Both reports tested (Two of two) were noncompliant for compliance an internal control purpose. 3) The annual report a. The one report tested was noncompliant for compliance an internal control purpose. Cause: The policies and procedures of the College did not ensure that grant reporting requirements were timely and accurately met. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: No. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Educational Stabilization Fund Assistance Listing Numbers: 84.425E ? Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F ? Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award Period: July 1, 2020, to June 30, 2021 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: During our testing of HEERF reporting requirements at Flagler College, we noted: 1) Non-Compliant Student Reporting a. Of the two student reports selected for testing, we were unable to determine that the reports were posted in the timeframe prescribed by the Department. 2) Non-Compliant Institutional Reporting a. One of the two institutional reports selected for testing was not posted on the College?s website. b. Two of the two institutional reports selected for testing did not agree to supporting documentation. 3) Non-Compliant Annual Reporting a. Total student expenditures in the annual report did not agree to supporting documentation. 4) Internal Control a. The review and approval control could not be traced to supporting records during testing for any report submitted. Questioned costs known: None. Context: There were 3 separate reporting requirements tested as part of the HEERF Program. Each of the reports had a unique number tested for both internal control and compliance. 1) Public reporting on the (a)(1) Student Aid Portion. a. One of the two reports tested were noncompliant for compliance purposes. b. Both reports tested (two of two) were noncompliant for internal control purposes. 2) Public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable. a. Both reports tested (Two of two) were noncompliant for compliance an internal control purpose. 3) The annual report a. The one report tested was noncompliant for compliance an internal control purpose. Cause: The policies and procedures of the College did not ensure that grant reporting requirements were timely and accurately met. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: No. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting responsibilities have been shifted to a different individual within the College, who is cognizant of all the requirements and deadlines for compliance. Since the initial discovery of the reporting issue, improved expense tracking within the general ledger has been implemented, as well as additional review procedures by the Controller and Manager of Student Accounts. All reports and deadlines are finalized by the VP of Business Services, who also ensures the reports are appropriately published on the College?s website. Name of contact person responsible for corrective action: Stacey Matthews, VP for Business Services. Planned completion date for corrective action plan: Corrective action will be completed by December 2022.
FAC accepted this audit on May 25, 2021 — management decision was due November 25, 2021.
During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 32 of 40 students tested had one or more instances of noncompliance noted below: I. 1 instance where the campus level enrollment effective date was not reported accurately. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. 2 instances where a student?s campus level enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) III. 32 instances where the program level student program begin date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. 9 instances where the program enrollment effective date was incorrectly reported. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned costs Known: None. Context: Out of a statistically valid sample of 40 students selected for testing for the requirement noted above, we noted 32 exceptions as described above. While the requirements for the campus level enrollment effective dates, program length, and program enrollment effective dates are not new, this is the first year this is required to be tested per the OMB Compliance Supplement. Cause: I. The campus and program level enrollment effective date errors were due to various process breakdowns as to how the student information system reported the dates to the third-party servicer. II. The two students reported late were due to the Office of the Registrar not reviewing the specific transmission error report provided by their third-party servicer. III. The published program length errors were due to various process breakdowns as to how the student information system reported the length to the third-party servicer. Effect: The NSLDS system is potentially not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat Finding: No. Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.268 Federal Direct Student Loan Program 84.063 Federal Pell Grant Program Award Period: July 1, 2019, to June 30, 2020 Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant Deficiency in Internal Controls over Compliance. Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). 32 of 40 students tested had one or more instances of noncompliance noted below: I. 1 instance where the campus level enrollment effective date was not reported accurately. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) II. 2 instances where a student?s campus level enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(2) and 34 CFR 690.83(b)(2) III. 32 instances where the program level student program begin date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. 9 instances where the program enrollment effective date was incorrectly reported. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) Questioned costs Known: None. Context: Out of a statistically valid sample of 40 students selected for testing for the requirement noted above, we noted 32 exceptions as described above. While the requirements for the campus level enrollment effective dates, program length, and program enrollment effective dates are not new, this is the first year this is required to be tested per the OMB Compliance Supplement. Cause: I. The campus and program level enrollment effective date errors were due to various process breakdowns as to how the student information system reported the dates to the third-party servicer. II. The two students reported late were due to the Office of the Registrar not reviewing the specific transmission error report provided by their third-party servicer. III. The published program length errors were due to various process breakdowns as to how the student information system reported the length to the third-party servicer. Effect: The NSLDS system is potentially not updated with correct student information which could cause over subsequent awarding issues or repayment term discrepancies. Repeat Finding: No. Recommendation: We recommend that the College enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely.
The errors in the program-level enrollment effective dates were caused by the process when a student submitted a change of major. To address the issue with the program effective dates, the College reviewed its policies and procedures for change of major and discovered data being entered into the Jenzabar system was impacting data being sent to the National Student Clearinghouse and ultimately being reported to NSLDS. Our IT department identified the students with the erroneous records and corrected them. Our Advising Office has modified their change of major process so that it will no longer impact the dates being reported to the National Student Clearinghouse. The Office of Financial Aid and the Office of the Registrar will be reviewing the SSCR and SCHER1 reports to ensure that all of the error records are corrected and resubmitted timely and accurately. Name(s) of the contact person(s) responsible for corrective action: Sheia Pleasant-Doine Planned completion date for corrective action plan: Implemented on April 28, 2021
FAC accepted this audit on October 31, 2018 — management decision was due May 1, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on November 7, 2017 — management decision was due May 7, 2018.
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2016-001
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FAC accepted this audit on November 21, 2016 — management decision was due May 21, 2017.
GSA_MIGRATION
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2015-001
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