EVERGLADES COLLEGE INC

Finding 2024-001 Identification of the Federal Program United States Department of Education 84.063 Federal Pell Grant Program Criteria: 34 CFR 668.22 Condition: Late Return of Title IV Funds (“R2T4”) Cause: No cause could be determined. Effect: Federal funds that would have been available to other eligible grant recipients and for relending were not available. Further, the United States Department of Education may have been subject to unnecessary interest and special allowance. Questioned Costs: $1,564 in 2023-2024 Federal Pell Grant program funds and $65 of potential interest owed to the United States Department of Education. Description of the Nature and Extent of the Issues Reported: The Institution had a total of eight thousand five hundred seventy five (8,575) students who withdrew during the audit period. We tested the files of twenty five (25) of those students. It was determined that one (1) R2T4 was not returned in a timely manner. For student #5, the Institution calculated the correct R2T4 amount but failed to return the correct amount. The Institution should have returned $1,564 in 2023-2024 Federal Pell Grant program funds in question in G5 no later than March 22, 2024. The Institution’s failure to return the correct amount resulted in the Federal Pell Grant program funds being returned 385 days late. As a result of the late return, the Institution also failed to update COD within 45 days. COD was updated on April 11, 2025, 385 days late. Subsequent to the audit, the Institution returned $1,564 to the Federal Pell Grant program on behalf of student #5. Additionally, the Institution issued a write-off of $1,564 on the student’s account. The instance of noncompliance represents an error rate in the number of sampled items tested equal to 4% (1 of 25) from a population of 8,575 and in the dollar amount of the sampled items tested equal to 0.6% ($1,564 of $259,137) from a population of $90,206,452. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendations: The Institution needs to review and update its procedures to ensure that all returns from R2T4 calculations are made in a timely manner. Views of Responsible Officials: The Institution agrees with the finding and recommendation. Upon review, the Institution has found this to be an isolated incident due to human error. See Corrective Action Plan for more details.

Finding 2021-001 Identification of the Federal Program: United States Department of Education Federal Direct Student Loans 84.268 Criteria: 34 CFR 668.22 Condition: Incorrect Return of Title IV Funds (?R2T4?) Cause: The Institution calculated the R2T4 using the wrong payment period end date for Step 2, resulting in an incorrect number of Total Days and percentage of payment period completed in Part H. Effect: Federal funds that would have been available to other eligible loan recipients and for relending were not available. Further, the United States Department of Education may have been subject to unnecessary interest and special allowance. Questioned Costs: $1,612 in 2020-2021 Subsidized Federal Direct Loan program funds and $19 in 2020-2021 Unsubsidized Federal Direct Loan program funds. Description of the Nature and Extent of the Issues Reported: The Institution had a total of ten thousand four hundred seventy one (10,471) students who withdrew during the audit period. We tested the files of twenty five (25) of those students. It was determined that one (1) R2T4 was not calculated correctly. For student #2, the R2T4 in question was returned on March 12, 2021, in the amount of $2,455 in 2020-2021 Unsubsidized Federal Direct Loan program funds. The Institution should have returned $2,474 in 2020-2021 Unsubsidized Federal Direct Loan program funds and $1,612 in 2020-2021 Subsidized Federal Direct Loan program funds, which resulted in an under return of $19 in 2020-2021 Unsubsidized Federal Direct Loan program funds and $1,612 in 2020-2021 Subsidized Federal Direct Loan program funds. The Institution calculated the R2T4 using the wrong payment period end date for Step 2, resulting in an incorrect number of Total Days and percentage of payment period completed in Part H. Subsequent to the audit, the Institution returned $1,612 to the 2020-2021 Subsidized Federal Direct Loan program and $19 to the 2020-2021 Unsubsidized Federal Direct Loan program funds on behalf of student #2. The instance of noncompliance represents an error rate in the number of sampled items tested equal to 4.0% (1 of 25) from a population of 10,471 and in the dollar amount of the sampled items tested equal to 1.23% ($1,631 of $132,131) from a population of $84,629,030. This is a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendations: The Institution needs to review and update its procedures to ensure that the R2T4 calculation process is completed correctly. Views of Responsible Officials: The Institution agrees with the finding and recommendation. To resolve the finding, the Institution returned the additional Direct Loan funds and awarded student #2 and institutional scholarship. The Institution has reviewed the instance of the finding and determined it to be an isolated incident. The Institution understands the importance of completing accurate Return to Title IV calculations. Additional training will be held to prevent the recurrence of this finding. The training will be held prior to June 30, 2022.

Finding 2020-001EU Identification of the Federal Program: Federal Award Identification: Federal Supplemental Educational Opportunity Grant Program (84.007) Criteria: 34 CFR 676.9 A student at an institution of higher education is eligible to receive an FSEOG for an award year if the student - (a) Meets the relevant eligibility requirements contained in 34 CFR 668.32; (b) Is enrolled or accepted for enrollment as an undergraduate student at the institution; and (c) Has financial need as determined in accordance with part F of title IV of the HEA. Condition: Over Award of Federal Supplemental Educational Opportunity Grant Program Funds. Cause: The institution mistakenly granted an award under the Federal Supplemental Educational Opportunity Grant Program to an ineligible student. Possible Adverse Effect: The student in question was not awarded properly based upon the student?s eligibility. Questioned Costs: Known questioned costs amount to $500 in Federal Supplemental Educational Opportunity Grant program funds, which was remediated. The likely questioned cost is under $25,000 (See Information to provide proper perspective for judging the prevalence and consequences of the audit finding). Information to provide proper perspective for judging the prevalence and consequences of the audit finding: For student #9, the Institution awarded $500 Federal Supplemental Educational Opportunity Grant program funds. The student was not eligible, resulting in an over award of $500. Subsequent to the finding discovery, the Institution refunded $500 in Federal Supplemental Educational Opportunity Grant program funds on behalf of student #9 and awarded an institutional scholarship for $500 to the student. The instance of noncompliance represents an error rate in the number of sampled items tested equal to 3.70% (1 of 27) from a population of 695 and in the dollar amount of the sampled items tested equal to 7.46% ($500 of $6,700) from a population of $173,750. This is a statistically valid sample. The extrapolated discrepancy amounts to $12,966. Recommendations: The Institution needs to review and update its procedures to ensure that all students are awarded properly. Views of Responsible Officials: A. Comments on Findings and Recommendations: We agree with the finding and recommendation for this finding. B. Actions Taken or Planned: The institution finds this is an isolated incident. To spend the 1920 Federal Supplemental Educational Opportunity Grant (FSEOG) a student was incorrectly awarded and approved to receive the funds. The institution understands students with an EFC that is not Pell eligible are ineligible to receive the FSEOG grant. Additional counseling was provided to the team that reviews eligibility. The FSEOG awarding process is documented in the institutions FSEOG procedures.

Finding 2020-002EU Identification of the Federal Program: Federal Award Identification: Federal Direct Loan Program (84.268) Criteria: 34 CFR 685.309 (b) Enrollment reporting process. (1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary Condition: Incorrect NSLDS Enrollment Reporting. Cause: Unflagged errors found on NSLDS reports require manual intervention which were not performed. Possible Asserted Effect: NSLDS was not properly notified of changes in students? statuses. Questioned Costs: There were no questioned costs. Information to provide proper perspective for judging the prevalence and consequences of the audit finding: Our review of 60 student files disclosed that the Institution?s records did not agree with NSLDS records for two students. For student #39, the Institution reported, for campus and program records, an effective date of March 30, 2020, for a withdrawn status to NSLDS. The correct effective date for the withdrawn status is March 16, 2020. For student #56, the Institution reported, for campus and program records, an effective date of August 30, 2020, for a graduated status to NSLDS. The correct status for the August 30, 2020 effective date is withdrawn. Subsequent to the audit, the Institution provided the auditors with proof of the corrections made in NSLDS for student #39 and Student #56. The instances of noncompliance represent an error rate in the number of sampled items tested equal to 3.33% (2 of 60) from a population of 1,734 and in the dollar amount of the sampled items tested equal to 0.00% ($0 of $669,605) from a population of $20,045,893. This is a statistically valid sample. Recommendations: The Institution needs to review and update its procedures to ensure that all reporting requirements are completed accurately and within the required time frame. Views of Responsible Officials: A. Comments on Findings and Recommendations: We agree with the finding and recommendation for the NSLDS enrollment reporting. B. Actions Taken or Planned: The institution has noted continued issues with NSLDS enrollment reporting and has reported incidents to the student information systems management team. The institution has procedures in place to correct errors that are found on NSLDS error reports. Additional errors that are not flagged by the NSLDS system require manual intervention. The institution has continued to work to identify the errors and develop procedures to assist in correcting the errors. The incidents are being reported to the student information systems team for review and correction.

Finding 2020-002KU Identification of the Federal Program: Federal Award Identification: Federal Pell Grant Program (84.063) Criteria: 34 CFR 690.63 (b) Programs using standard terms with at least 30 weeks of instructional time. The Federal Pell Grant for a payment period, i.e., an academic term, for a student in a program using standard terms with at least 30 weeks of instructional time in two semesters or trimesters or in three quarters as described in paragraph (a)(1)(ii)(A) of this section, is calculated by -(1) Determining his or her enrollment status for the term; (2) Based upon that enrollment status, determining his or her annual award from the Payment Schedule for full-time students or the Disbursement Schedule for three-quarter-time, half-time, or less-than-half-time students; and (3) Dividing the amount described under paragraph (b)(2) of this section by -(i) Two at institutions using semesters or trimesters or three at institutions using quarters; or (ii) The number of terms over which the institution chooses to distribute the student's annual award if -(A) An institution chooses to distribute all of the student's annual award determined under paragraph (b)(2) of this section over more than two terms at institutions using semesters or trimesters or more than three quarters at institutions using quarters; and (B) The number of weeks of instructional time in the terms, including the additional term or terms, equals the weeks of instructional time in the program's academic year.Condition: An award from the Federal Pell Grant Program Funds was understated. Cause: The award was miscomputed and a member of the team responsible for the review process approved the miscomputed award. Possible Asserted Effect: The student in question was not awarded $1,450 based upon the student?s eligibility. The award initially computed was not in excess of the required computation under the program. Questioned Costs: There were no questioned costs. The award was understated. Information to provide proper perspective for judging the prevalence and consequences of the audit finding: For student #18, the Institution awarded $1,248 in 2020-2021 Federal Pell Grant program funds. The student was eligible for $2,698, resulting in an under award of $1,450 in 2020-2021 Federal Pell Grant program funds. Subsequent to the finding discovery, the Institution awarded and disbursed $1,450 in 2020-2021 Federal Pell Grant program funds to student #18. The instance of noncompliance represents an error rate in the number of sampled items tested equal to 1.67% (1 of 60) from a population of 18,062 and in the dollar amount of the sampled items tested equal to 0.00% ($0 of $209,359) from a population of $82,994,440. Recommendations: The Institution needs to review and update its procedures to ensure that all students are properly awarded financial assistance. Views of Responsible Officials: A. Comments on Findings and Recommendations: We agree with the finding and recommendation for this finding. B. Actions Taken or Planned: The institution has found this is an isolated incident. During the review process the incorrect amount of Pell was approved in error. As part of the procedures in the file review process the students schedule is reviewed to determine Pell eligibility. Additional counseling has been provided to the team responsible for the review process to ensure procedures in place are followed.

Finding 2019-001 Federal Award Identification: Federal Pell Grant Program and Federal Direct Loan Program- CFDA 84.063 and 84.268 Criteria: 34 CFR 685.301 (a)(2) (iii) 34 CFR 690.61(a) A school must provide to the Secretary [student] information that includes but is not limited to? [t]he ? actual disbursement date or dates and disbursement amounts of the loan proceeds or grants, as determined in accordance with ? 685.303(d). ?an institution must disburse a Federal Pell Grant to an eligible student who is otherwise qualified to receive that disbursement and electronically transmit Federal Pell Grant disbursement data to the Secretary for that student? Condition: The date of certain disbursements provided to the Department of Education Common Origination and Disbursement (`COD?) differs from the actual date of disbursements. Cause: The University uses a third-party software platform as electronic data interchange to update the records of applicable student loans and grants in the COD. In certain circumstances, generally when there is a non-recurring status change of a student such as a refund adjustment, the interchange defaults to providing a date other than the actual date of disbursement. The University was relying on the internal controls of the third-party software to provide the respective actual date of disbursement. Possible Asserted Effect: The difference in dates between certain actual disbursements and those provided to the COD differed within a range of 2 to 24 days. There are no exceptions on all other information tested related to the criteria. Questioned Costs: There are no questioned costs related to the finding. Information to provide proper perspective for judging the prevalence and consequences of the audit finding: There were no exceptions found during the testing of the internal controls over compliance of the criteria for each major federal program. Pursuant to our testing of compliance, 13 out of a sample 60 students had one or more disbursement dates posted to the COD which differed from the actual date. Such disbursements aggregated $48,842 out of a sample of $874,349. The sampling was a statistically valid sample. This represents an exception rate of 6% of the sampled federal expenditures. The University raised the issue with the third-party software provider which is working to provide a long-term fix. The only other solution available is to manually update the correct date of the disbursements within the COD. The University provided evidence that the misstated disbursement dates identified pursuant to our testing of compliance were corrected. Recommendations: The Institution needs to update and implement its monitoring control activities to ensure that date of disbursements provided to the COD do not differ from the actual date of disbursements. Views of Responsible Officials: A. Comments on Findings and recommendations: We agree with the finding and recommendation. During the 2019 calendar year the institution experienced import issues that caused the date discrepancy between COD and student ledgers. B. Actions Taken or Planned: The Institution will be monitoring dates intently to ensure this finding is not continued. The institution is developing a procedure so that future disbursements have the correct date reported. The Student Financial Services and Student Financial Operations team will be responsible for monitoring the development of the procedure and working with the institutions reconciliation team to ensure om-going review of disbursement dates matching. A review of disbursements and COD dates will be done by the reconciliation staff from the Student Financial Operations team, to confirm dates match and to ensure this finding is not continued. Should any unforeseen circumstances occur throughout the year student Title IV disbursements will be reviewed against the COD system to ensure correct dates are correct.

Finding 2019-002 Criteria: 34 CFR 685.304 Condition: Late Exit Counseling Cause: No cause could be determined. Effect: Not completing exit counseling increases the likelihood of default. Description of the Nature and Extent of the Issues Reported: Our review of sixty (60) student files disclosed that the Institution sent late exit counseling materials to two (2) students (student #12 and student #43). Although late, the exit counseling materials were mailed to the students in question. Questioned Costs: There were no questioned costs. The instances of noncompliance represents an error rate in the number of sampled items equal to 3.3% (2 of 60) from a population of 24,575 and in the dollar amount of the sampled items tested equal to 0.0% ($0 of $874,349) from a population of $307,439,676. Recommendations: The Institution needs to review and update its procedures to ensure that all students are provided exit counseling within the required timeframe. Views of Responsible Officials: A. Comments on Findings and Recommendations: We agree with the finding and recommendation. The error from 2019 was due to employee turnover which delayed the processing of Exit Interview letters. When new staff was hires to take over the process student Exit material was captured and mailed to those students. B. Actions Taken or Planned: The Institution has reviewed the finding. The institution found that the students who received late exit counseling material were due to human error. The Associate Vice Chancellor Student Financial Services has reviewed Exit Counseling procedures and will be implementing a policy to ensure graduate students receive Exit counseling material timely. A review of this policy and training for campus staff will be held.

Finding 2019-003 Criteria: 34 CFR 685.309 Condition: Incorrect NSLDS Enrollment Reporting Cause: No cause could be determined. Effect: NSLDS was not properly notified of changes in students? statuses. Description of the Nature and Extent of the Issues Reported: Our review of sixty (60) student files disclosed that the Institution?s records did not agree with NSLDS records for three (3) students. For student #23, student #27, and student #29, the Institution reported the incorrect Last Day of Attendance (?LDA?) to NSLDS. Subsequent to the audit, the Institution provided the auditors with proof of the corrections made in NSLDS for student #23, student #27, and student #29. Questioned Costs: There were no questioned costs. The instances of noncompliance represents an error rate in the number of sampled items equal to 5.0% (3 of 60) from a population of 24,575 and in the dollar amount of the sampled items tested equal to 0.0% ($0 of $874,349) from a population of $307,439,676. Recommendations: The Institution needs to review and update its procedures to ensure that all reporting requirements are completed accurately and within the required time frame. Views of Responsible Officials: A. Comments on Findings and Recommendations: We agree with the finding and recommendation. The error in NSLDS reporting was due to incorrect data transfer for the student?s enrollment history and data was pulling from the wrong information in the student information system. B. Actions Taken or Planned: The institution is working with the student information system team as well as its IT staff to identify the issue with the enrollment reporting and incorrect information that is being transmitted to NSLDS. By September 30, 2020, the NSLDS team will begin reviewing the NSLDS process weekly in order to identify the error that occurred. The institution Is working with the IT staff to identify the error in enrollment reporting data and will continue reviewing NSLDS information weekly until a resolution is provided. Also, new procedures will be implemented to ensure transfer students are recorded correctly in the student information system so correct enrollment data is reported to NSLDS. This new procedure will be implemented by September 30, 2020 and will be shared with the campus staff and the NSLDS review team. The Institution was not required to take any corrective actions as indicated on the prior audit report issued by Boisseau, Felicione & Associates, Inc. on July 23, 2019, covering the Student Financial Assistance Cluster: Federal Pell Grant, Federal Direct Loan, Federal Supplemental Educational Opportunity Grant, Federal Work-Study, and Federal Perkins Loan programs for the period ending December 31, 2018.