Connors State College

Federal Agency: US Department of Education Federal Program Name: Higher Education Institutional Aid Assistance Listing Number: 84.031X Federal Award Identification Number and Year: P031X230004 - 2025, P031X200017 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1)(vi), Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal 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. Condition: The College did not have proper documentation of Time and Effort reporting. Questioned costs: None. Context: During our testing of 40 payroll transactions, we identified four employees’ time and effort reports that were not documented properly to track hours worked on federal grants. Cause: The College did not have proper procedures in place to track time and effort for all personnel on federal grants. Effect: The College could potentially expend incorrect amounts to federal grants. Repeat Finding: No Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.18(g) require institutions to use at least 7% of the sum of its initial and supplemental Federal Work Study allocation for an award year to compensate students employed in community service activities unless a waiver is obtained from the Department of Education. Per 2 CFR 200.303, nonfederal 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. Condition: The College did not meet the community service requirement for its Federal Work Study program. Questioned costs: None. Context: The College did not use at least 7% of its Federal Work Study (FWS) funds for students employed in community service activities. Cause: Due to several staff turnovers in the Financial Aid Office, the community service waiver request was discovered to not have been completed by the submission deadline. Effect: If the College fails to meet any of the FWS community service requirements, then they will be required to return FWS federal funds in an amount equal to the difference between the amount a school should have spent for community service and the amount it actually spent. The College could also be denied future participation in the FWS Program and possibly other FWS programs. Repeat Finding: No Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: During testing of Common Origination and Disbursement (COD) reporting, we noted one instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we noted, one Pell disbursement was not reported within the required 15 days. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The amount of a student's 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) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Per 2 CFR 200.303, nonfederal 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. Condition: The College under-awarded funds for the Pell Grant. Questioned costs: $909 Context: During our testing, we identified one out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 2024-2025 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Student Aid Index and the enrollment status of the student. Cause: The College did not have proper procedures in place to capture student enrollment in summer to be packaged for Pell. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding: Yes, 2024-005 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None Context: During our testing of 40 students, we identified four students that had Program enrollment effective dates that did not match institutional records and one student that was reported after the 60- day reporting requirement. Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately and submitted timely. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding:  Compliance, Other Matter  Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal 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. Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations. Questioned costs: ALN 84.063 $615 ALN 84.268 $2,722 Context: During our testing of 17 R2T4 calculations, we identified that 2 had a mechanically incorrect calculation. Cause: The College did not maintain proper documentation of withdrawal date for R2T4 calculations. Effect: The College could return incorrect amounts based off their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: Yes, 2024-001 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal 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." Condition The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and did not have formal procedures in place to document review of calculations. Questioned costs: Known $341.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Effect The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding No Recommendation We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal 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. " Condition The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately. Effect The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding No Recommendation We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately.

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Test and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal 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." Condition The College did not properly notify students when loans were credited to student's ledger account. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified that there were 5 students that did not receive the required notification of Direct Loan disbursements. Cause Due to staff turnover, loan notifications were missed being sent out to students. Effect Students were not made aware of the anticipated date and amount of loan disbursement for the right to cancel all or a portion of the loan in the required amount of time. Repeat Finding No Recommendation We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.038, 84.063, 84.268 Federal Award Identification Number and Year P007A233410 - 2024, P033A233410 - 2024, P063P232032 - 2024, P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal 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." Condition The College did not properly have documentation of exit counseling notification. Questioned costs: N/A Known Likely Context During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding No Recommendation We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.063 Federal Award Identification Number and Year P063P232032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. 34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Per 2 CFR 200.303, nonfederal 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." Condition The College under-awarded funds for the Pell Grant. Questioned costs: Known $6,472.00 Likely See Questioned Cost Tab Context During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester Effect Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding No Recommendation We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials Agree

Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Award Identification Number and Year P268K24032 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Cash Management Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR 685.300(b)(5)) and the Federal Student Aid Handbook, Volume 4, Chapter 6, states loan reconciliation is a mandatory monthly process requiring the comparison of both internal and external records to be completed by an institution participating in the Direct Loan Program. Reconciliation is conducted to identify and resolve differences between net draws and disbursements reported to the Common Origination and Disbursement for a specific award year. An institution must document the reasons and resolve the discrepancies identified during the reconciliation process and that a review had been performed. Per 2 CFR 200.303, nonfederal 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." Condition The College did not have documentation that Direct Loan Reconciliation was performed. Questioned costs: N/A Known Likely Context During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Effect Failure to perform reconciliations timely could result in errors going undetected by student financial aid management. Repeat Finding No Recommendation We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Views of Responsible Officials Agree

Student Financial Assistance Cluster, CFDA Number 84.063 Federal Pell Grant Program, CFDA Number 84.268 Federal Direct Student Loans, U.S. Department of Education Program Year 2019?2020 Criteria or Specific Requirement ? Special Tests and Provisions: Enrollment Reporting 34 CFR Sections 690.83(b)(2) and 685.309 Condition ? A total of 9 student enrollment status changes were not communicated to the National Student Loan Data System (NSLDS) on a timely basis. Additionally, a total of 35 of 250 attributes tested did not agree between the NSLDS and institutional records. Questioned Costs ? None Context ? Out of the population of 1140 students with enrollment status changes requiring reporting to NSLDS, a sample of 25 student enrollment status changes was selected for testing. 9 student enrollment status changes were not reported to NSLDS within the required 60 days. An additional 35 student data attributes on 18 students did not agree between NSLDS and institutional records. Our sample was not, and was not intended to be, statistically valid. Effect ? NSLDS was not notified of student enrollment status changes for Direct Loan and Pell Grant recipients in a timely or accurate manner. Cause ? A staffing change in the VP of Academic Affairs, Registrar and Financial Aid Office caused a failure in timely reporting. Also, change in staff resulted in a lack of training for the registrar who does the reporting through the National Clearinghouse (NCH), and it was noted that NCH is dropping students from the roster when students start and stop school more than twice. When the student restarts, the report is submitted to NCH; however, it is treated as a mistake and is not forwarded to NSLDS. Indication as a Repeat Finding ? Prior year finding 2019-001 Recommendation ? The College should review its procedures for reporting student enrollment status changes for students receiving Direct Loans and Pell Grants. Views of Responsible Officials and Planned Corrective Actions ? Both the registrar and director of FAO will work closely together to compare monthly reports being sent to NCH for changes. The registrar will work through the error reports received from NCH. Also, in working with IT, we have found and are correcting CIP code issues. We will run reports and compare to ensure necessary changes have been made to correct CIP codes for future terms. We will also be double checking withdrawn students who are returning and those who are not returning to ensure they are correctly reported at the first of term. The registrar plans on completing a more robust investigation of rejected NCH student records and completing follow-up, focused on the code given for the rejection in reconciliation of our student records with those of NCH. This is an alternative to past practices, as the registrar has noticed a reduction in the types and amounts of rejected records that have been received while completing the process and based on past enrollment report submissions. The current registrar never got to this stage of training as timing did not allow for a smooth transition. He has since been able to advance his knowledge and learn the proper handling of rejected records in a more timely manner.