EIN: 621861520
UEI: ZLR6RPGEG9M3
Audited by: David A Levy CPA
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 4, 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 August 4, 2026 (24 days ago).
What is a management decision? →FINDING 2025-001: NSLDS Status Reporting Error CRITERIA: In accordance with 34 CFR 682.610 (c), Institutions are to report the enrollment statusof students who received Title IV aid to NSLDS. This enrollment information is updated inNSLDS and, as appropriate, is reported to guarantors, lenders, and servicers of federal student loans. A student’s enrollment status determines eligibility for in-school status, deferment andgrace periods as well as for the Department’s payment of interest subsidies to loan holders.SSCR/Enrollment Reporting is not only critical for effective administration of the Title IV student loan programs, but is also required so that the Department can engage in budgetary and policyanalysis. CONDITION: Some student statuses were not reported to NSLDS on time. CAUSE: The Institution did not follow its ordinary procedures to ensure that NSLDS enrollmentreporting was submitted in a timely manner. EFFECT: The USDOE does not have timely information pertaining to student's enrollment statuseswhich can affect loan deferments among other things. NATURE, EXTENT OF ISSUE, AND QUESTIONED COSTS: In 14 instances out of 35 files reviewed,of which NSLDS data for 24 students were reviewed, the students’ enrollment status changes werenot reported to NSLDS in a timely manner. No. of Students FPELL FDLP FSEOG Total Universe 74 286,427 710,426 14,045 1,010,898 Sample Size 35 110,482 358,073 5,000 473,555 Sample for this Attribute 35 110,482 358,073 5,000 473,555 Instances of Non Compliance 14 25,625 171,953 1,000 198,578 Level of Materiality Material RECOMMENDATION: We also recommend that the Institution enact stronger controls to ensure thatall future enrollment reporting is submitted both correctly and timely. VIEWS OF RESPONSIBLE OFFICIAL: The Institution concurs with this finding and has proceduresin place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴FINDING 2025-001: NSLDS Status Reporting Error CRITERIA: In accordance with 34 CFR 682.610 (c), Institutions are to report the enrollment statusof students who received Title IV aid to NSLDS. This enrollment information is updated inNSLDS and, as appropriate, is reported to guarantors, lenders, and servicers of federal student loans. A student’s enrollment status determines eligibility for in-school status, deferment andgrace periods as well as for the Department’s payment of interest subsidies to loan holders.SSCR/Enrollment Reporting is not only critical for effective administration of the Title IV student loan programs, but is also required so that the Department can engage in budgetary and policyanalysis. CONDITION: Some student statuses were not reported to NSLDS on time. CAUSE: The Institution did not follow its ordinary procedures to ensure that NSLDS enrollmentreporting was submitted in a timely manner. EFFECT: The USDOE does not have timely information pertaining to student's enrollment statuseswhich can affect loan deferments among other things. NATURE, EXTENT OF ISSUE, AND QUESTIONED COSTS: In 14 instances out of 35 files reviewed,of which NSLDS data for 24 students were reviewed, the students’ enrollment status changes werenot reported to NSLDS in a timely manner. No. of Students FPELL FDLP FSEOG Total Universe 74 286,427 710,426 14,045 1,010,898 Sample Size 35 110,482 358,073 5,000 473,555 Sample for this Attribute 35 110,482 358,073 5,000 473,555 Instances of Non Compliance 14 25,625 171,953 1,000 198,578 Level of Materiality Material RECOMMENDATION: We also recommend that the Institution enact stronger controls to ensure thatall future enrollment reporting is submitted both correctly and timely. VIEWS OF RESPONSIBLE OFFICIAL: The Institution concurs with this finding and has proceduresin place as outlined in the Corrective Action Plan to ensure compliance with requirements.
AUDIT FINDING Finding 2025-001 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS MANAGEMENT'S We concur with the auditor’s finding and identification of a deficiency in our internal controls. CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all future enrollment reporting is submitted timely. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FINDING 2024-001: Incorrect Title IV (R2T4) Calculation CRITERIA: In accordance with 34 CFR 668.22(1) 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. CONDITION: The Institution calculated the R2T4 incorrectly. CAUSE: The Institution did not follow its ordinary procedures to accurately and timely perform R2T4 calculations. EFFECT: The Institution over returned Title IV funds. NATURE, EXTENT OF ISSUE, AND QUESTIONED COSTS: In two instances out of 50 files reviewed, of which 25 students withdrew, the Institution calculated the R2T4 incorrectly. Both instances resulted in over refunding Title IV funds that were earned by the Institution. This is not considered a material finding. No. of Students FPELL FDLP FSEOG Total Universe 128 434,190 1,308,216 13,725 1,756,131 Sample Size 50 170,171 408,716 6,600 585,487 Sample for this Attribute 25 84,494 193,091 3,500 281,085 Instances of Non Compliance 2 1,968 597 200 2,765 Level of Materiality Immaterial RECOMMENDATION: We recommend the Institution review all withdrawn students to ensure that all R2T4 calculations are completed, accurate, and the required funds are returned the USDOE. VIEWS OF RESPONSIBLE OFFICIAL: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴FINDING 2024-001: Incorrect Title IV (R2T4) Calculation CRITERIA: In accordance with 34 CFR 668.22(1) 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. CONDITION: The Institution calculated the R2T4 incorrectly. CAUSE: The Institution did not follow its ordinary procedures to accurately and timely perform R2T4 calculations. EFFECT: The Institution over returned Title IV funds. NATURE, EXTENT OF ISSUE, AND QUESTIONED COSTS: In two instances out of 50 files reviewed, of which 25 students withdrew, the Institution calculated the R2T4 incorrectly. Both instances resulted in over refunding Title IV funds that were earned by the Institution. This is not considered a material finding. No. of Students FPELL FDLP FSEOG Total Universe 128 434,190 1,308,216 13,725 1,756,131 Sample Size 50 170,171 408,716 6,600 585,487 Sample for this Attribute 25 84,494 193,091 3,500 281,085 Instances of Non Compliance 2 1,968 597 200 2,765 Level of Materiality Immaterial RECOMMENDATION: We recommend the Institution review all withdrawn students to ensure that all R2T4 calculations are completed, accurate, and the required funds are returned the USDOE. VIEWS OF RESPONSIBLE OFFICIAL: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
AUDIT FINDING Finding 2024-001 Incorrect Title IV (R2T4) Calculation MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor’s finding and identification of a deficiency in our internal controls. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all R2T4s are accurately calculated and the proper amounts are refunded in a timely manner. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
The Institution returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds in a timely manner. Effect: The Institution may owe interest on funds returned late. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which 25 students withdrew, the Institution returned the correct amount of Title IV funds beyond the allowable time frame. In this instance, the Institution returned the correct amount of funds 85 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴Finding 2022-001: Late Return to Title IV (R2T4) Criteria: In accordance with 34 CFR 668.22(1) 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. Condition: The Institution returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds in a timely manner. Effect: The Institution may owe interest on funds returned late. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which 25 students withdrew, the Institution returned the correct amount of Title IV funds beyond the allowable time frame. In this instance, the Institution returned the correct amount of funds 85 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
AUDIT FINDING Finding 2022-001 Late Return to Title IV (R2T4) MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor?s finding and identification of a deficiency in our internal controls. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all R2T4s are returned in a timely manner. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately
2021-001
One student status was not reported to NSLDS in a timely manner. Cause: The Institution did not follow its ordinary procedures to ensure that NSLDS enrollment reporting was submitted correctly and in a timely manner. Effect: The USDOE does not have timely information pertaining to student's enrollment status which can affect loan deferments among other things. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which NSLDS data for 45 students was reviewed, the students? enrollment status change was not reported to NSLDS in a timely manner. In this instance, the withdrawn status was first reported to NSLDS 205 days after the student?s last date of attendance. Recommendation: We recommend that the Institution enact stronger controls to ensure that all future enrollment reporting is submitted timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴Finding 2022-002: NSLDS Status Reporting Error Criteria: In accordance with 34 CFR 682.610 (c), Institutions are to report the enrollment status of students who received Title IV aid to NSLDS. This enrollment information is updated in NSLDS and, as appropriate, is reported to guarantors, lenders, and servicers of federal student loans. A student?s enrollment status determines eligibility for in-school status, deferment and grace periods as well as for the Department?s payment of interest subsidies to loan holders. SSCR/Enrollment Reporting is not only critical for effective administration of the Title IV student loan programs, but is also required so that the Department can engage in budgetary and policy analysis. Condition: One student status was not reported to NSLDS in a timely manner. Cause: The Institution did not follow its ordinary procedures to ensure that NSLDS enrollment reporting was submitted correctly and in a timely manner. Effect: The USDOE does not have timely information pertaining to student's enrollment status which can affect loan deferments among other things. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 65 files reviewed, of which NSLDS data for 45 students was reviewed, the students? enrollment status change was not reported to NSLDS in a timely manner. In this instance, the withdrawn status was first reported to NSLDS 205 days after the student?s last date of attendance. Recommendation: We recommend that the Institution enact stronger controls to ensure that all future enrollment reporting is submitted timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
AUDIT FINDING Finding 2022-002 NSLDS Status Reporting Error MANAGEMENT'S COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the auditor?s finding and identification of a deficiency in our internal controls. MANAGEMENT'S CORRECTIVE ACTION PLAN We will enact stronger controls to ensure that all future enrollment reporting is submitted timely. EMPLOYEE/ DIVISION RESPONSIBLE Financial Aid Director TIMELINE AND ESTIMATED COMPLETION DATE Immediately
FAC accepted this audit on February 28, 2022 — management decision was due August 28, 2022.
The Institution returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds accurately and/or timely. The COVID-19 pandemic caused considerable staffing disturbances in the financial aid department during the audit period. Effect: The Institution may owe interest on funds returned late. Nature, Extent of Issue, and Questioned Costs: In 4 instances out of 85 files reviewed, of which 25 students withdrew, the Institution returned the correct amount of Title IV funds beyond the allowable time frame. In the first instance, the Institution returned the correct amount of funds 15 days beyond the allowable time frame. In the second instance, the Institution returned the correct amount of funds 174 days beyond the allowable time frame. In the third instance, the Institution returned the correct amount of funds 84 days beyond the allowable time frame. In the fourth instance, the Institution returned the correct amount of funds 18 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴CURRENT AUDIT Finding 2021-001: Late Return to Title IV (R2T4) Criteria: In accordance with 34 CFR 668.22(1) 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. Condition: The Institution returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds accurately and/or timely. The COVID-19 pandemic caused considerable staffing disturbances in the financial aid department during the audit period. Effect: The Institution may owe interest on funds returned late. Nature, Extent of Issue, and Questioned Costs: In 4 instances out of 85 files reviewed, of which 25 students withdrew, the Institution returned the correct amount of Title IV funds beyond the allowable time frame. In the first instance, the Institution returned the correct amount of funds 15 days beyond the allowable time frame. In the second instance, the Institution returned the correct amount of funds 174 days beyond the allowable time frame. In the third instance, the Institution returned the correct amount of funds 84 days beyond the allowable time frame. In the fourth instance, the Institution returned the correct amount of funds 18 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
AUDIT FINDING Finding 2021-001 Late Return to Title IV (R2T 4) MANAGEMENT'S We concur with the auditor's finding and identification of a significant COMMENTS ON FINDINGS deficiency in our internal controls. AND RECOMMENDATIONS MANAGEMENT'S We have enacted stronger controls to ensure that all R2T 4s are returned CORRECTIVE ACTION PLAN in a timely manner. During the audit year, the Institution's internal controls over financial aid were strengthened to be able to incorporate remote workers and teams, as presented itself during the pandemic, and as such identified the errors and processed the returns prior to the audit commencmg. EMPLOYEE/ DIVISION Financial Aid Director RESPONSIBLE TIMELINE AND ESTIMATED The Institution returned all funds prior to the audit commencing COMPLETION DATE AlJDIT FINDING Finding 2020-001 Incorrect/Late Return to Title IV (R2T4) MANAGEMENT'S We concur with the auditor's finding and identification of a significant COMMENTS ON FINDINGS deficiency in our internal controls. AND RECOMMENDATIONS MANAGEMENT'S We will enact stronger controls to ensure that all R2T 4s are calculated CORRECTIVE ACTION PLAN correctly and returned in a timely manner. We will return the $779 of FDLP funds identified in this finding. EMPLOYEE/ DIVISION Financial Aid Director RESPONSIBLE TIMELINE AND ESTIMATED Immediately COMPLETION DATE VISIBLE MUSIC COLLEGE 200 MADISON A VENUE MEMPHIS, TN 38103 CORRECTIVE ACTION PLAN FOR THE FISCAL YEAR ENDED JUNE 30, 2021 Audit Firm: David A Levy CPA PC Audit Period: July 1, 2020 - June 30, 2021 CURRENT AUDIT PRIOR AUDIT CURRENT STA TlJS: This finding reoccurred in the current audit. See finding 2021-001. AUDIT FINDING Finding 2020-002 Funds Disbursed Beyond Maximum Timeframe MANAGEMENT'S We concur with the auditor's finding and identification of a significant COMMENTS ON FINDINGS deficiency in our internal controls. AND RECOMMENDATIONS MANAGEMENT'S We will enact stronger controls and undergo additional training to ensure CORRECTIVE ACTION PLAN that no students receive Title IV funds beyond the maximum timeframe. We will return the $10,291 of Title IV funds identified in this finding. EMPLOYEE/ DIVISION Financial Aid Director RESPONSIBLE TIMELINE AND ESTIMATED Immediately COMPLETION DATE CURRENT STATUS: This finding did not reoccur in the current audit due to the implementation of stronger controls. AUDIT FINDING Finding 2020-003 Missing Entrance Counseling MANAGEMENT'S We concur with the auditor's finding and identification of a deficiency COMMENTS ON FINDINGS in our internal controls. AND RECOMMENDATIONS MANAGEMENT'S We will add additional safeguards to ensure that all future students who CORRECTIVE ACTION PLAN plan to receive FDLP funds perform entrance counseling. EMPLOYEE/ DIVISION Financial Aid Director RESPONSIBLE TIMELINE AND ESTIMATED Immediately COMPLETION DATE CURRENT STATUS: This finding did not reoccur in the current audit due to the implementation of stronger controls.
2020-001
FAC accepted this audit on June 30, 2021 — management decision was due December 30, 2021.
The Institution either returned the incorrect amount of Title IV funds or returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds accurately and/or timely. Effect: The Institution under returned Title IV funds and may owe interest on funds returned late or that have not yet been returned. Nature, Extent of Issue, and Questioned Costs: In 5 instances out of 85 files reviewed, of which 25 students withdrew, the Institution either calculated the R2T4 incorrectly or returned the correct amount of Title IV funds beyond the allowable time frame. In the first instance, the Institution returned the correct amount of funds 146 days beyond the allowable time frame. In the second instance, the Institution returned the correct amount of funds 38 days beyond the allowable time frame. In the third instance, the Institution returned the correct amount of funds 134 days beyond the allowable time frame. In the fourth instance, the Institution under returned $779 in FDLP funds. In the fifth instance, the Institution returned the correct amount of funds 120 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely and accurately. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴Finding 2020-001: Incorrect/Late Return to Title IV (R2T4) Criteria: In accordance with 34 CFR 668.22(1) 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. Condition: The Institution either returned the incorrect amount of Title IV funds or returned the correct amount of Title IV funds beyond the allowable time frame. Cause: The Institution did not follow its ordinary procedures in returning Title IV funds accurately and/or timely. Effect: The Institution under returned Title IV funds and may owe interest on funds returned late or that have not yet been returned. Nature, Extent of Issue, and Questioned Costs: In 5 instances out of 85 files reviewed, of which 25 students withdrew, the Institution either calculated the R2T4 incorrectly or returned the correct amount of Title IV funds beyond the allowable time frame. In the first instance, the Institution returned the correct amount of funds 146 days beyond the allowable time frame. In the second instance, the Institution returned the correct amount of funds 38 days beyond the allowable time frame. In the third instance, the Institution returned the correct amount of funds 134 days beyond the allowable time frame. In the fourth instance, the Institution under returned $779 in FDLP funds. In the fifth instance, the Institution returned the correct amount of funds 120 days beyond the allowable time frame. Recommendation: We recommend the Institution review its policies and procedures regarding R2T4 and enact stronger controls to ensure that all future returns are performed timely and accurately. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Audit Finding Finding 2020-001 Incorrect/Late Return to Title IV (R2T4)Management's Comments on Findings And Recommendations We concur with the auditor?s finding and identification of a significant deficiency in our internal controls. Management's Corrective Action Plan We will enact stronger controls to ensure that all R2T4s are calculated correctly and returned in a timely manner. We will return the $779 of FDLP funds identified in this finding. Employee/ Division Responsible Financial Aid Director Timeline and Estimated Completion Date Immediately
The institution disbursed Title IV funds beyond 150% of the scheduled program length. Cause: The Institution did not follow its ordinary procedures to ensure that students did not receive Title IV funds beyond the maximum timeframe. Effect: Students contained in this finding received Title IV funds that they were not eligible to receive. Nature, Extent of Issue, and Questioned Costs: In 2 instances out of 85 files reviewed, the Institution disbursed Tile IV funds to students beyond the maximum time frame. In the first instance, the institution disbursed $4,701 of FDLP funds and $523 of Pell funds beyond the maximum timeframe. In the second instance, the Institution disbursed $1,894 of FDLP funds and $3,173 of Pell funds beyond the maximum timeframe. The Institution must return all funds received after the maximum time frame totaling $10,291 ($6,595 FDLP, $3,696 Pell). Recommendation: We recommend that the Institution enact stronger controls to ensure that all Title IV funds are disbursed within the maximum timeframe. Views of Responsible Officials: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴Finding 2020-002: Funds Disbursed Beyond Maximum Timeframe Criteria: In accordance with 34 CFR 668.34(b)(1), a student must complete the program within the maximum timeframe as defined as 150% of the published length of the educational program. Condition: The institution disbursed Title IV funds beyond 150% of the scheduled program length. Cause: The Institution did not follow its ordinary procedures to ensure that students did not receive Title IV funds beyond the maximum timeframe. Effect: Students contained in this finding received Title IV funds that they were not eligible to receive. Nature, Extent of Issue, and Questioned Costs: In 2 instances out of 85 files reviewed, the Institution disbursed Tile IV funds to students beyond the maximum time frame. In the first instance, the institution disbursed $4,701 of FDLP funds and $523 of Pell funds beyond the maximum timeframe. In the second instance, the Institution disbursed $1,894 of FDLP funds and $3,173 of Pell funds beyond the maximum timeframe. The Institution must return all funds received after the maximum time frame totaling $10,291 ($6,595 FDLP, $3,696 Pell). Recommendation: We recommend that the Institution enact stronger controls to ensure that all Title IV funds are disbursed within the maximum timeframe. Views of Responsible Officials: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Audit Finding Finding 2020-002 Funds Disbursed Beyond Maximum Timeframe Management's Comments on Findings And Recommendations We concur with the auditor?s finding and identification of a significant deficiency in our internal controls. Management's Corrective Action Plan We will enact stronger controls and undergo additional training to ensure that no students receive Title IV funds beyond the maximum timeframe. We will return the $10,291 of Title IV funds identified in this finding. Employee/ Division Responsible Financial Aid Director Timeline and Estimated Completion Date Immediately
The Institution could not provide entrance counseling for the student identified in this finding. Cause: The Institution did not follow its ordinary procedures in ensuring that all students who receive FDLP funds complete entrance counseling. Effect: The student identified in this finding may not have been notified that they must repay their loans leading to potential late payment penalties, additional interest charges and default. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 85 files reviewed, of which 77 students received FDLP funds, the Institution could not provide entrance counseling. The student subsequently withdrew and was notified of their obligation to complete exit counseling. Recommendation: The Institution should apply additional precautions to ensure that its existing policies requiring entrance counseling are adhered to for all applicable students. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Show full finding ▾Hide full finding ▴Finding 2020-003: Missing Entrance Counseling Criteria: In accordance with 34 CFR 685.304, the Institution is to conduct both entrance and exit counseling with the students, to review their borrowing obligations, including loan repayment and debt-management strategies. Condition: The Institution could not provide entrance counseling for the student identified in this finding. Cause: The Institution did not follow its ordinary procedures in ensuring that all students who receive FDLP funds complete entrance counseling. Effect: The student identified in this finding may not have been notified that they must repay their loans leading to potential late payment penalties, additional interest charges and default. Nature, Extent of Issue, and Questioned Costs: In 1 instance out of 85 files reviewed, of which 77 students received FDLP funds, the Institution could not provide entrance counseling. The student subsequently withdrew and was notified of their obligation to complete exit counseling. Recommendation: The Institution should apply additional precautions to ensure that its existing policies requiring entrance counseling are adhered to for all applicable students. Views of Responsible Official: The Institution concurs with this finding and has procedures in place as outlined in the Corrective Action Plan to ensure compliance with requirements.
Audit Finding Finding 2020-003 Missing Entrance Counseling Management's Comments on Findings And Recommendations We concur with the auditor?s finding and identification of a deficiency in our internal controls. Management's Corrective Action Plan We will add additional safeguards to ensure that all future students who plan to receive FDLP funds perform entrance counseling. Employee/ Division Responsible Financial Aid Director Timeline and Estimated Completion Date Immediately
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FINDING 2019-001 ? Cyber Security Deficiency CONDITION: The Institution has not yet completed the implementation of an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to an unauthorized access. RECOMMENDATION: 2019-001-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-001-b ? The Institution should consider attending additional training courses to better understand ED rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding and will implement his recommendations.
Show full finding ▾Hide full finding ▴FINDING 2019-001 ? Cyber Security Deficiency CONDITION: The Institution has not yet completed the implementation of an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to an unauthorized access. RECOMMENDATION: 2019-001-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-001-b ? The Institution should consider attending additional training courses to better understand ED rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding and will implement his recommendations.
December 9, 2019 U.S. Department of Education 500 W. Madison Street, Suite 1414 Chicago, IL 60661 To Whom It May Concern: Visible School, Inc. d/b/a Visible Music College respectfully submits the following corrective action plan for the year ended June 30, 2019. If you have any questions or concerns regarding this plan, please do not hesitate to contact me at 901-381-3939. A. Current Year Findings: FINDING 2019-001 ? Cyber Security Deficiency CONDITION: The Institution has not yet completed the implementation of an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to an unauthorized access. RECOMMENDATION: 2019-001-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-001-b ? The Institution should consider attending additional training courses to better understand ED rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding and will implement his recommendations.
FAC accepted this audit on March 9, 2018 — management decision was due September 9, 2018.
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