EIN: 620730291
UEI: GSA_MIGRATION
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 8, 2022. 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 8, 2022 (1449 days ago).
What is a management decision? →We tested forty-one files and enrollment status effective dates were incorrectly reported to the National Student Loan Data System (NSLDS) for four students. The Institution did not provide enrollment update responses in a timely manner for all six reporting periods. Due to the nature of this finding, we have qualified our opinion for this attribute. Cause: The condition was caused by reporting the date of determination, instead of the actual last day of attendance for students. Additionally, the institution was not aware of the bi-monthly requirement to report within fifteen days of the distribution email from NSLDS. Effect: The result is the Department of Education was not made aware of the changes in student statuses in a timely manner and four students? enrollment dates were reported to NSLDS inaccurately. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: As the Institution has since updated the student effective dates in NSLDS and provided proof of correction, we recommend the Institution tighten controls over Enrollment Reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-002: INACCURATE AND UNTIMELY ENROLLMENT STATUS REPORTING (MATERIAL WEAKNESS) FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN: 84.063 & 84.268 FEDERAL AWARD YEAR: 2020-2021 & 2021-2022 Compliance Requirement: Reporting 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-one files and enrollment status effective dates were incorrectly reported to the National Student Loan Data System (NSLDS) for four students. The Institution did not provide enrollment update responses in a timely manner for all six reporting periods. Due to the nature of this finding, we have qualified our opinion for this attribute. Cause: The condition was caused by reporting the date of determination, instead of the actual last day of attendance for students. Additionally, the institution was not aware of the bi-monthly requirement to report within fifteen days of the distribution email from NSLDS. Effect: The result is the Department of Education was not made aware of the changes in student statuses in a timely manner and four students? enrollment dates were reported to NSLDS inaccurately. Question Costs: $0 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: As the Institution has since updated the student effective dates in NSLDS and provided proof of correction, we recommend the Institution tighten controls over Enrollment Reporting. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Findings and Recommendations We agree with the auditors in regard to this finding. We were unaware of the proper timeline for the reporting periods. This will be corrected in the future per the action plan implemented Actions Taken or Planned As we have since updated the inaccurately reported students in NSLDS and provided proof to our auditors, we will add a procedure to add an additional review of all students? information monthly, assuring that all reports to NSLDS are accurate and that this does not happen in the future. Additionally, we have contracted with a financial aid servicer, FAS, Inc. , which will assure that our reporting and corrections to all NSLDS reporting is provided within the required 15 days (maximum) from the date of initial contact for our bi-monthly reporting throughout the audit period, as well as decreasing the opportunity for any/all errors in the future.
We tested 19 drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by not inputting Title IV aid in the proper areas of Step 1 of the Return to Title IV Calculation (R2T4). Effect: The result is the Institution retained funds that should have been returned to the Department of Education. Question Costs: $1,189 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: As the Institution has since returned $1,189 to the Department of Education and provided proof of the correction. We recommend the Institution increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-003: INCORRECT REFUND CALCULATION FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN: 84.063 & 84.268 FEDERAL AWARD YEAR: 2020-2021 & 2021-2022 Compliance Requirement: Returns of Title IV Funds Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested 19 drop students and found one incorrect refund calculation. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by not inputting Title IV aid in the proper areas of Step 1 of the Return to Title IV Calculation (R2T4). Effect: The result is the Institution retained funds that should have been returned to the Department of Education. Question Costs: $1,189 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: As the Institution has since returned $1,189 to the Department of Education and provided proof of the correction. We recommend the Institution increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Findings and Recommendations We agree with the auditors in regard to this finding. Proper calculations will be made in the future per the action plan implemented. Actions Taken or Planned The refund calculation was performed per our normal process, but a simple error was made by inputting funds in both ?disbursed? and ?Could?ve been disbursed? in Step 1 of the R2T4. As we have since returned the $1,189 to the Department of Education and provided our auditors with proof, we will increase controls over Returns to Title IV Calculations. Additionally, our auditors reviewed all student files from our Drop Universe, a total of 19, assuring there are no additional errors. Lastly, as mentioned above, we have contracted with a financial aid servicer, who will also be performing our R2T4s beginning in the 2022 audit period.
We tested 19 drop students and found one late refund. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid office. Effect: The result is the Institution retained funds that should have been returned to the Department of Education. Question Costs: $2,145 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: As there was no further corrective action required, we recommend the Institution increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING 2021-004: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM AND FEDERAL DIRECT LOAN PROGRAM ALN: 84.063 & 84.268 FEDERAL AWARD YEAR: 2020-2021 & 2021-2022 Compliance Requirement: Returns of Title IV Funds Criteria: 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 19 drop students and found one late refund. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid office. Effect: The result is the Institution retained funds that should have been returned to the Department of Education. Question Costs: $2,145 Statistical sampling was not used when making sample selections. See Schedule of findings and questioned costs for chart/table. Recommendation: As there was no further corrective action required, we recommend the Institution increase controls over refund calculations. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.
Findings and Recommendations We agree with the auditors in regard to this finding. All refunds will be submitted timely per the action plan implemented. Actions Taken or Planned The refund was calculated accurately, but due to a timing issue with our attendance reporting and the student no longer adhering to our attendance policy, the refund was calculated and returned a bit late. Based on review of all our drop students, this was an isolated incident. Per our auditors, no further action is required. Again, as mentioned above, our auditors have reviewed all the student files from our drop universe and we have contracted a financial aid servicer and they will be performing our R2T4 calculations and assuring timeliness in refunds, if necessary.
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