EIN: 710246213
UEI: LQ5VVQY25V39
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 26, 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 September 26, 2026 (32 days from today).
What is a management decision? →During our audit, we noted that federal funds available under the grant were drawn in advance and were used for purposes other than those stated in the grant agreement. Criteria: In accordance with 2 CFR 200.304(a), costs must be “necessary and reasonable for the performance of the Federal award”. Also, per 2 CFR 200.305(b), “Advance payments to a recipient or subrecipient must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the recipient or subrecipient in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the recipient or subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs.” Effect of Condition: Federal funds were inappropriately drawn in advance and used on unallowable costs. Questioned Costs: The questioned costs total $9,574,454, which represent federal funds drawn in advance and used for purposes other than stated in the grant agreement. Cause of Condition: The College does not consistently follow its policies and procedures related to federal grant funding. Recommendation: We recommend that the College enforce its cash management policy and ensure that controls surrounding cash management of federal funds are in accordance with 2 CFR 200.305(b). Management’s Response: Management agrees and will submit a Corrective Action Plan.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services – Health Resources and Services Administration Finding 2025-004: Material Weakness in Internal Control and Material Noncompliance – Allowable Costs/Cost Principles & Cash Management – Community Project Funding/Congressional Directives Program #93.493 Statement of Condition: During our audit, we noted that federal funds available under the grant were drawn in advance and were used for purposes other than those stated in the grant agreement. Criteria: In accordance with 2 CFR 200.304(a), costs must be “necessary and reasonable for the performance of the Federal award”. Also, per 2 CFR 200.305(b), “Advance payments to a recipient or subrecipient must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the recipient or subrecipient in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the recipient or subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs.” Effect of Condition: Federal funds were inappropriately drawn in advance and used on unallowable costs. Questioned Costs: The questioned costs total $9,574,454, which represent federal funds drawn in advance and used for purposes other than stated in the grant agreement. Cause of Condition: The College does not consistently follow its policies and procedures related to federal grant funding. Recommendation: We recommend that the College enforce its cash management policy and ensure that controls surrounding cash management of federal funds are in accordance with 2 CFR 200.305(b). Management’s Response: Management agrees and will submit a Corrective Action Plan.
Finding 2025-004: Material Weakness in Internal Control and Material Noncompliance – Allowable Costs/Cost Principles & Cash Management – Community Project Funding/Congressional Directives Program Corrective Action: The College will strengthen oversight of federal grant cash management and compliance with federal regulations. Management will review and enforce existing cash management policies to ensure that federal funds are drawn only as needed for allowable costs and in accordance with 2 CFR 200.305. Additional internal controls will be implemented to ensure that grant expenditures are reviewed for allowability and that drawdowns are properly timed with actual program expenditures. Management has reviewed the grant activity related to the questioned costs identified during the audit. Prior to the completion of the audit fieldwork, all equipment associated with the grant had been purchased in accordance with the grant’s approved purposes. The College will continue to monitor expenditures and grant activity to ensure that all remaining grant funds are used in compliance with federal requirements and the terms of the grant agreement. Proposed Completion Date: June 30, 2026
FAC accepted this audit on March 17, 2025 — management decision was due September 17, 2025.
From our testing sample of ten (10) students, we found seven (7) instances where changes in student status due to withdrawal were not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Effect of Condition: We found seven (7) instances where changes in student status due to withdrawal were not reported timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2024-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of ten (10) students, we found seven (7) instances where changes in student status due to withdrawal were not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Effect of Condition: We found seven (7) instances where changes in student status due to withdrawal were not reported timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: The “Timely Reporting” issue resulted from a misunderstanding in the Registrar’s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office’s personnel and established procedures designed to prevent it from happening in the future. The “Funds Not Returned Timely” reflects continued improvements resulting from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce compliance with the attendance monitoring and reporting policy, as well as refine procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2025
2023-002
From our testing sample of ten (10) students, we found ten (10) instances where the incorrect dates of the academic calendar were used to calculate the percentage of the semester attended. Criteria: In accordance with Volume 3 Chapter 1 of the Federal Student Aid Handbook, “the number of weeks of instructional time is based on the period that generally begins on the first day of classes in the academic year and ends on the last day of classes or the last day of examinations, whichever is later”. Effect of Condition: We found ten (10) instances where the last of classes (instead of the last day of finals) was used on the student’s R2T4 calculations. Cause of Condition: The College believed the last day of classes was considered the last day of the academic period. Recommendation: We recommend the College develop policies and procedures to address this issue. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2024-003: Policies and Procedures Related to Withdrawals – SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of ten (10) students, we found ten (10) instances where the incorrect dates of the academic calendar were used to calculate the percentage of the semester attended. Criteria: In accordance with Volume 3 Chapter 1 of the Federal Student Aid Handbook, “the number of weeks of instructional time is based on the period that generally begins on the first day of classes in the academic year and ends on the last day of classes or the last day of examinations, whichever is later”. Effect of Condition: We found ten (10) instances where the last of classes (instead of the last day of finals) was used on the student’s R2T4 calculations. Cause of Condition: The College believed the last day of classes was considered the last day of the academic period. Recommendation: We recommend the College develop policies and procedures to address this issue. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: We have used the last day of finals to be the last day in the payment period for any withdrawals in the 2024-2025 academic year. Proposed Completion Date: June 30, 2025
From our testing sample of twenty-five (25) students, we found three (3) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30-days of the disbursement to the student’s account. Criteria: Federal loans, including PLUS Loans, should be disbursed in accordance with Volume 3 of the Federal Student Aid Handbook. Also, in accordance with 34 CFR 668.165, Notices and Authorizations, an institution must notify the student or parent of the date and amount of disbursement of Federal loans to a student’s ledger account within 30-days of the disbursement. Effect of Condition: We found three (3) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30-days of the disbursement to the student’s account. Cause of Condition: The College did have a policy to notify parents of their student’s PLUS Loan disbursements until the spring semester of 2024, when the prior audit finding was brought to the attention of management. Recommendation: We recommend the College develop policies and procedures to address this issue. Management’s Response: Management agrees and has a policy in place to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2023-004 (continuing finding): Policies and Procedures Related to Packaging Student Financial Aid – SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of twenty-five (25) students, we found three (3) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30-days of the disbursement to the student’s account. Criteria: Federal loans, including PLUS Loans, should be disbursed in accordance with Volume 3 of the Federal Student Aid Handbook. Also, in accordance with 34 CFR 668.165, Notices and Authorizations, an institution must notify the student or parent of the date and amount of disbursement of Federal loans to a student’s ledger account within 30-days of the disbursement. Effect of Condition: We found three (3) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30-days of the disbursement to the student’s account. Cause of Condition: The College did have a policy to notify parents of their student’s PLUS Loan disbursements until the spring semester of 2024, when the prior audit finding was brought to the attention of management. Recommendation: We recommend the College develop policies and procedures to address this issue. Management’s Response: Management agrees and has a policy in place to implement these recommendations immediately.
Corrective Action: The Financial Aid Office notifies student of federal loan disbursements to their accounts, but was not aware that parent PLUS loan borrowers were required to be notified of PLUS loan disbursements. Beginning with the fall ’24 semester, the FAO has begun notifying PLUS loan borrowers of those disbursements to student accounts. Financial Aid is working with the internal IT department to assist with sending these notices in a timely manner. Proposed Completion Date: June 30, 2025
2023-004
FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.
From our testing sample of ten (10) students, we found one (1) instance where changes in student status due to withdrawal were not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Also in accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that return calculations can be performed and any refunds can be made within forty-five (45) days after the date of the school’s determination that the student has withdrawn. Effect of Condition: We found one (1) instance where changes in student status due to withdrawal were not reported timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2023-002 (continuing finding): Policies and Procedures Related to Withdrawals – SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of ten (10) students, we found one (1) instance where changes in student status due to withdrawal were not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student’s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Also in accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that return calculations can be performed and any refunds can be made within forty-five (45) days after the date of the school’s determination that the student has withdrawn. Effect of Condition: We found one (1) instance where changes in student status due to withdrawal were not reported timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: The "Timely Reporting" issue resulted from a misunderstanding in the Registrar's Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office's personnel and established procedures designed to prevent it from happening in the future. The "Funds Not Returned Timely" reflects continued improvements resultig from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2024
2022-002
From our testing sample of thirty-five (35) students, we found eight (8) instances where student award letters were not retained and thus federal award data per the federal award register could not be vouched. Criteria: Student records should be retained in accordance with the Federal Student Aid Handbook, Volume 2, Chapter 7, to “show a clear audit trail for FSA program expenditures.” In addition, the College’s Financial Aid Office Policies for Awarding Financial Aid states “a copy of the student’s award letter is kept in the student’s folder.” Effect of Condition: We found eight (8) instances where student award letters were not retained. Cause of Condition: The College does not consistenly follow their internal policies. Recommendation: We recommend the College develop policies and procedures to address this issue. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2023-003: Policies and Procedures Related to Packaging Student Financial Aid (significant deficiency) Statement of Condition: From our testing sample of thirty-five (35) students, we found eight (8) instances where student award letters were not retained and thus federal award data per the federal award register could not be vouched. Criteria: Student records should be retained in accordance with the Federal Student Aid Handbook, Volume 2, Chapter 7, to “show a clear audit trail for FSA program expenditures.” In addition, the College’s Financial Aid Office Policies for Awarding Financial Aid states “a copy of the student’s award letter is kept in the student’s folder.” Effect of Condition: We found eight (8) instances where student award letters were not retained. Cause of Condition: The College does not consistenly follow their internal policies. Recommendation: We recommend the College develop policies and procedures to address this issue. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: Since all full-time students receive institutional aid, they must all have an aid package in our system in order for us to disburse that aid to their account. All new students would need to be presented with an award offer in order to make decisions about any financial responsibilitiy created by enrolling at Lyon College, so I believe all students received award offers. Going forward, the new (manual) digital file system will be more familiar to us and the learning curve less steep. Our normal process will include placing a copy of the award letter in every student's digital file. We will add a process to be run after the census date of each semester - as well as at later dates in the semester - to make sure that every full-time student and every student with federal aid has a digital file that includes a copy of their award offer, even those who submit a FAFSA after classes have begun for the semester. Proposed Completion Date: June 30, 2024
From our testing sample of twenty-five (25) students, we found nine (9) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30 days of the disbursement to the student’s account. Criteria: Federal loans, including PLUS Loans, should be disbursed in accordance with Volume 3 of the Federal Student Aid Handbook. Also, in accordance with 34 CFR 668.165, Notices and Authorizations, an institution must notify the student or parent of the date and amount of disbursement of Federal loans to a student’s ledger account within 30-days of the disbursement. Effect of Condition: We found nine (9) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30-days of the disbursement to the student’s account. Cause of Condition: The College does not have a policy to notify parents of their students’ PLUS Loan disbursements. Recommendation: We recommend the College develop a policy and procedure to address this issue. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2023-004: Policies and Procedures Related to Packaging Student Financial Aid – SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of twenty-five (25) students, we found nine (9) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30 days of the disbursement to the student’s account. Criteria: Federal loans, including PLUS Loans, should be disbursed in accordance with Volume 3 of the Federal Student Aid Handbook. Also, in accordance with 34 CFR 668.165, Notices and Authorizations, an institution must notify the student or parent of the date and amount of disbursement of Federal loans to a student’s ledger account within 30-days of the disbursement. Effect of Condition: We found nine (9) instances where the student’s parent was not notified of the disbursement of a PLUS Loan within 30-days of the disbursement to the student’s account. Cause of Condition: The College does not have a policy to notify parents of their students’ PLUS Loan disbursements. Recommendation: We recommend the College develop a policy and procedure to address this issue. Management’s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: The Financial Aid Office notifies student of federal loan disbursements to their accounts, but was not aware that parent PLUS loan borrowers were required to be notified of PLUS loan disbursements. Beginning with the fall '24 semester, the FAO has begun notifying PLUS loan borrowers of those disbursements to student accounts. Projected Completion Date: June 30, 2024
FAC accepted this audit on March 13, 2023 — management decision was due September 13, 2023.
From our testing sample of ten (10) students, we found five (5) instances where changes in student status due to withdrawal were not reported timely and one (1) instance where the Title IV funds were not returned timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student?s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Also in accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that return calculations can be performed and any refunds can be made within forty-five (45) days after the date of the school?s determination that the student has withdrawn. Effect of Condition: We found five (5) instances where changes in student status due to withdrawal were not reported timely and we one (1) instance where the Title IV funds were not returned timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2022-002: Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of ten (10) students, we found five (5) instances where changes in student status due to withdrawal were not reported timely and one (1) instance where the Title IV funds were not returned timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student?s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Also in accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, all students who withdraw and receive Title IV funds should be identified so that return calculations can be performed and any refunds can be made within forty-five (45) days after the date of the school?s determination that the student has withdrawn. Effect of Condition: We found five (5) instances where changes in student status due to withdrawal were not reported timely and we one (1) instance where the Title IV funds were not returned timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Finding 2022-002: Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Corrective Action: The ?Timely Reporting? issue resulted from a misunderstanding in the Registrar?s Office regarding the requirements of what had to be reported and by when. We have discussed this issue with that office?s personnel and established procedures designed to prevent it from happening in the future. The ?Funds Not Returned Timely? reflects continued improvements resulting from policies already established to enhance compliance with attendance reporting and tracking of those reports by the Registrar and Financial Aid Offices. The College will continue to reinforce compliance with the attendance monitoring and reporting policy, as well as refine procedures for active monitoring of those reports by these two offices. In particular, the process of evaluating whether students who are on the two-week absence report in any one class are in fact at risk of falling out of enrollment status overall. Proposed Completion Date: June 30, 2023
From our testing sample of twenty-five (25) students, we found two (2) instances where students financial aid was incorrectly packaged. One (1) student was over-awarded a federal direct subsidized loan and one (1) student was over-awarded a federal direct subsidized loan. Criteria: Federal direct loans should be disbursed in accordance with the Federal Student Aid Handbook, Volume 3. Also, in accordance with 34 CFR 668.59, Consequences of a Change in an Applicant?s FAFSA Information, if an applicant?s FAFSA information changes, the student?s financial aid package should be recalculated. Effect of Condition: We found two (2) instances where students financial aid was incorrectly packaged. One (1) student was over-awarded a federal direct subsidized loan and one (1) student was over-awarded a federal direct subsidized loan. Cause of Condition: The College does not have a policy in place to review the packaging of student financial aid. The College also does not have a policy in place to review FAFSA information changes for the repackaging of student financial aid. Recommendation: We recommend the College develop policies and procedures to address these issues. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2022-003: Policies and Procedures Related to Packaging Student Financial Aid ? SFA Cluster (significant deficiency) Statement of Condition: From our testing sample of twenty-five (25) students, we found two (2) instances where students financial aid was incorrectly packaged. One (1) student was over-awarded a federal direct subsidized loan and one (1) student was over-awarded a federal direct subsidized loan. Criteria: Federal direct loans should be disbursed in accordance with the Federal Student Aid Handbook, Volume 3. Also, in accordance with 34 CFR 668.59, Consequences of a Change in an Applicant?s FAFSA Information, if an applicant?s FAFSA information changes, the student?s financial aid package should be recalculated. Effect of Condition: We found two (2) instances where students financial aid was incorrectly packaged. One (1) student was over-awarded a federal direct subsidized loan and one (1) student was over-awarded a federal direct subsidized loan. Cause of Condition: The College does not have a policy in place to review the packaging of student financial aid. The College also does not have a policy in place to review FAFSA information changes for the repackaging of student financial aid. Recommendation: We recommend the College develop policies and procedures to address these issues. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Finding 2022-003: Policies and Procedures Related to Packaging Student Financial Aid ? SFA Cluster (significant deficiency) Corrective Action: Lyon College has two employees in the Financial Aid office. We do have a process in place to review the packaging of new student aid (FTFT and TXFR), though it is very manual, and requires both FA employees to be involved (in order to separate duties). It is still not foolproof. Our current software will not prevent us from overpackaging subsidized loans in our manual packaging process, but we can run a report to check and see if the field marked `Awards to Report as Need-Based? is greater than the field marked `Original Need?. If any are found, we can make the necessary adjustment. In the packaging of returning students ? the larger group of students - we do not have a review process in place. We will review to see if we can find a practical way, with our current limited personnel, to implement a review process for returning student award packages. The overpackaged student was simply a human keystroke error. Sub (remaining need) was calculated to be $4,484 and we input $4,884, a transposition. This was a returning student who likely did not get reviewed, and we also failed to pick it up in the process described below, comparing original need to awards marked as need. Our current software will not prevent us from overpackaging subsidized loans in our manual packaging process, but we can run a report to check and see if the field marked `Awards to Report as Need-Based? is greater than the field marked `Original Need?. If any are found, we can make the necessary adjustment. The other student was underpackaged with subsidized loans. In this case, the student was packaged on 7/15 based off of the only FAFSA we had available at that time, received on 6/29. On that FAFSA, the student had an EFC of $28,180, and no need. Therefore, all loans ($7,500) were packaged as unsubsidized. A PLUS loan denial came in the next day and the additional $5,000 was also packaged as unsubsidized. On 8/4, a revised FAFSA came in showing an EFC of $5,119. No adjustment was made to reclassify part of the loans as subsidized based on the `need? shown on the revised FAFSA. The Financial Aid Office believes that running the comparison report mentioned above on a regular basis will help us to find over-packaged need-based loans that we either made a mistake on during our initial packaging process, or due to a revised FAFSA that created additional need. Proposed Completion Date: The FAO will begin running the `Original Need vs. Aid Packaged As Need? Report on a monthly basis, and most importantly, in August immediately before aid is originated and disbursed.
FAC accepted this audit on March 31, 2022 — management decision was due October 1, 2022.
Per the 2021 Compliance Supplement, the College is required to publicly post student and institutional reports for HEERF II to their website on a quarterly basis. The College did not publicly post the reports for HEERF to their website on a quarterly basis. The College also did not post all of the required information in the student reports for HEERF II. Criteria: The 2021 Compliance Supplement requires that institutions publicly post the required reports to the institution?s website by the tenth day following the end of each calendar quarter, with the exception of the due date for Q1 2021, which was extended to June 30, 2021. Effect of Condition: As the College did not publicly post the reports for HEERF II to their website on a quarterly basis, and as the College did not post all of the required information in the student reports, the College was not in compliance with the HEERF reporting requirements. Cause of Condition: The errors were due to a lack of clarity/uncertainty with the HEERF II reporting requirements. Recommendation: We recommend that the College develop and implement procedures to ensure that reports are posted and are accurate. Management?s Response: Management agrees and corrected the reports as soon as management was made aware of the requirements by publicly posting the required student and institutional reports for HEERF on the Lyon College website and by posting all of the required information in the student reports for HEERF.
Show full finding ▾Hide full finding ▴U.S. Department of Education Finding 2021-002: Higher Education Emergency Relief Fund II (HEERF) Reporting (significant deficiency) Statement of Condition: Per the 2021 Compliance Supplement, the College is required to publicly post student and institutional reports for HEERF II to their website on a quarterly basis. The College did not publicly post the reports for HEERF to their website on a quarterly basis. The College also did not post all of the required information in the student reports for HEERF II. Criteria: The 2021 Compliance Supplement requires that institutions publicly post the required reports to the institution?s website by the tenth day following the end of each calendar quarter, with the exception of the due date for Q1 2021, which was extended to June 30, 2021. Effect of Condition: As the College did not publicly post the reports for HEERF II to their website on a quarterly basis, and as the College did not post all of the required information in the student reports, the College was not in compliance with the HEERF reporting requirements. Cause of Condition: The errors were due to a lack of clarity/uncertainty with the HEERF II reporting requirements. Recommendation: We recommend that the College develop and implement procedures to ensure that reports are posted and are accurate. Management?s Response: Management agrees and corrected the reports as soon as management was made aware of the requirements by publicly posting the required student and institutional reports for HEERF on the Lyon College website and by posting all of the required information in the student reports for HEERF.
Lyon College respectfully submits the following corrective action plan pursuant to the Major Federal Award Programs Audit Findings for the year ended June 30, 2021. Name of contact person: Joseph D. Botana ? Interim Vice-President for Business and Finance Finding 2021-001: Preparation of GAAP Financial Statements (significant deficiency) Corrective Action: The College believes that we have the expertise and means to prepare the GAAP Financial Statements. However, we believe that is more practical and efficient use of resources to continue to have the auditors prepare them. The college accounting staff will continue to remain informed about updated GAAP requirements and to perform careful review of the statements prepared by the auditors prior to final issuance. The accounting staff will also ensure that all year-end adjustments and closing entries are completed prior to the start of the audit for the year ended 6/30/22 and all subsequent years. Proposed Completion Date: June 30, 2022 Finding 2021-001: Higher Education Emergency Relief Fund II (HEERF) Reporting (significant deficiency) Corrective Action: The College corrected the reports and posted them prominently on the Lyon College website as soon as we were made aware of the specific requirements of the guidance. All of the required student and institutional reports were prepared or updated and posted months ago, since shortly after the requirements in the guidance were correctly understood. Proposed Completion Date: Completed as of December 31, 2021
FAC accepted this audit on June 17, 2021 — management decision was due December 17, 2021.
This is a continuing finding from the prior audit. From our testing sample of ten (10) students, we found three (3) instances where a change in student status due to withdrawal was not reported timely and three (3) instances where the Title IV funds were not returned timely. This is a continuing finding from the prior year (Finding 2019-001). Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student?s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Also in accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, all students who withdraw and receive Title IB funds should be identified so that return calculations can be performed and any refunds can be made within forty-five (45) days after the date of the school?s determination that the student has withdrawn. Effect of Condition: We found one (1) instance where a change in student status due to withdrawal was not reported timely and we found three (3) instances where the students Title IV funds were not returned within the required time frame. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴U.S. Department of Education Finding 2020-001 (continuing finding): Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Statement of Condition: This is a continuing finding from the prior audit. From our testing sample of ten (10) students, we found three (3) instances where a change in student status due to withdrawal was not reported timely and three (3) instances where the Title IV funds were not returned timely. This is a continuing finding from the prior year (Finding 2019-001). Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student?s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Also in accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, all students who withdraw and receive Title IB funds should be identified so that return calculations can be performed and any refunds can be made within forty-five (45) days after the date of the school?s determination that the student has withdrawn. Effect of Condition: We found one (1) instance where a change in student status due to withdrawal was not reported timely and we found three (3) instances where the students Title IV funds were not returned within the required time frame. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Finding 2020-001 (continuing finding): Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Corrective Action: The Financial Aid Office will continue the procedure of including all institutional educational-related charges on the R2T4 form when processing student withdrawals and calculating amounts of federal aid to be returned. The Financial Aid Office and the Business Office will work closely with the Provost to once again reemphasize, to the appropriate campus personnel, the importance of following the College's attendance-taking policy, and communicating that attendance information to the Registrar on a timely basis so as to allow the determination of the last date of class attendance (and therefore the effective date of withdrawal) required for the completion of the Student Withdrawal Form the Financial Aid Office uses to calculate and return Title IV funds in accordance with U.S. Department of Education regulations. In order to ensure that students who are not attending classes are reported timely to the Financial Aid Office so that Title IV withdrawal calculations can be performed as required, the College will adopt procedures requiring the Registrar?s Office to do the following (1) when a student is reported on ?early warning? in one class for non-attendance, query all of the student?s professors about their attendance in those classes, and (2) when a student is reported for a third or fourth absence in one class, query all of the student?s professors about their attendance in those classes. The Financial Aid office will be notified promptly when such inquiries indicate that a student is not attending multiple classes and may be a candidate for a status change. (This procedure was implemented in 2020 but too late to impact the year currently under audit and was also adversely affected by actions taken in response to the Covid-19 pandemic.) As an additional measure to ensure that students who are not attending classes and are otherwise disengaged from the college are timely identified, a report will be run weekly to show students who have not logged into their college network accounts for over one week. Monitored systems will include Schoology (LMS) and G-Suite (email and other services) as well as the wireless network. IT will inform the Registrar, Financial Aid, and Business Office weekly as students are identified to facilitate timely action. Proposed Completion Date: For enhanced communication of timely attendance to the Registrar and Financial Aid the new report: June 30, 2021 - in time for the start of the new academic year.
2019-001
The College does not have a written procurement policy. This is a continuing finding from the prior year (Finding 2019-002). Criteria: Under Title 2 U.S Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR Parts 200.317 through 200.326, the financial management system of each non-federal entity must have a written procurement policy. Cause of Condition: The College does not have a written policy that meets the Uniform Guidance requirements. Effect of Condition: The College is not in compliance with the Uniform Guidance. Recommendation: We recommend the College develop and implement a written procurement policy to comply with the requirements of the Uniform Guidance. The policy should be clearly documented and available for all College staff to follow. Management?s Response: Management agrees. The College established a written procurement policy in accordance with the requirements of the Uniform Guidance, which became effective on July 1, 2020.
Show full finding ▾Hide full finding ▴Finding 2020-002 (continuing finding): Written Procurement Policy (significant deficiency) Statement of Condition: The College does not have a written procurement policy. This is a continuing finding from the prior year (Finding 2019-002). Criteria: Under Title 2 U.S Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR Parts 200.317 through 200.326, the financial management system of each non-federal entity must have a written procurement policy. Cause of Condition: The College does not have a written policy that meets the Uniform Guidance requirements. Effect of Condition: The College is not in compliance with the Uniform Guidance. Recommendation: We recommend the College develop and implement a written procurement policy to comply with the requirements of the Uniform Guidance. The policy should be clearly documented and available for all College staff to follow. Management?s Response: Management agrees. The College established a written procurement policy in accordance with the requirements of the Uniform Guidance, which became effective on July 1, 2020.
Finding 2020-002 (continuing finding): Written Procurement Policy (significant deficiency) Corrective Action: The College has established a written procurement policy that complies with the requirement established by the Uniform Guidance. Proposed Completion Date: The College has implemented the above policy as of July 1, 2020.
2019-002
From our testing sample of eight (8) students, we found one (1) student who was paid Federal Work Study funds incorrectly. Criteria: In accordance with 34 CFR 675. l 6(a)(2) and (5), Payments to Students, an institution must pay a student Federal Work Study compensation at least once a month. Effect of Condition: The student in our sample was not paid on a monthly basis. Cause of Condition: The College's current policies require timesheets to be provided to the Business Office on a monthly basis to allow for students to be paid for compensation actually earned each month; however, the policy was not followed in this instance. Recommendation: We recommend that policies and procedures are consistently followed to strengthen the College's internal control structure related to Federal Work Study in order for the College to comply with applicable federal regulations. Management's Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2020-003: Payment of Federal Work Study Funds ? 84.033 (significant deficiency) Statement of Condition: From our testing sample of eight (8) students, we found one (1) student who was paid Federal Work Study funds incorrectly. Criteria: In accordance with 34 CFR 675. l 6(a)(2) and (5), Payments to Students, an institution must pay a student Federal Work Study compensation at least once a month. Effect of Condition: The student in our sample was not paid on a monthly basis. Cause of Condition: The College's current policies require timesheets to be provided to the Business Office on a monthly basis to allow for students to be paid for compensation actually earned each month; however, the policy was not followed in this instance. Recommendation: We recommend that policies and procedures are consistently followed to strengthen the College's internal control structure related to Federal Work Study in order for the College to comply with applicable federal regulations. Management's Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Finding 2020-003: Payment of Federal Work Study Funds ? 84.033 (significant deficiency) Corrective Action: Lyon College will implement a process to train supervisors of FWS employees about the importance of complying with the requirement to verify and report the hours worked on a monthly basis. In addition, the College will establish a process whereby HR/Payroll will follow up with supervisors who have not turned in time cards within one week after month end, and will follow up on any remaining delinquent timecards with supervisors and their component VP?s. Further, the College will implement a technology-based system for recording, approving, and reporting hours worked for FWS students. Proposed Completion Date: Lyon College will implement the above procedure by June 30, 2021, in time for the start of the next fiscal year.
FAC accepted this audit on March 25, 2020 — management decision was due September 25, 2020.
This is a continuing finding from the prior audit. From our testing sample of ten (10) students, we found one (1) instance where a change in student status due to withdrawal was not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student?s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Effect of Condition: We found one (1) instance where a change in student status due to withdrawal was not reported timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2019-001 (continuing finding): Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Statement of Condition: This is a continuing finding from the prior audit. From our testing sample of ten (10) students, we found one (1) instance where a change in student status due to withdrawal was not reported timely. Criteria: In accordance with 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdrawals, any changes to a student?s enrollment status are required to be reported within thirty (30) days, or within sixty (60) days if a roster file is expected within that time frame. Effect of Condition: We found one (1) instance where a change in student status due to withdrawal was not reported timely. Cause of Condition: The College does not consistently follow their attendance taking policy, which allows notification to the Financial Aid Office for students that may need to have a Title IV withdrawal calculation. Recommendation: We recommend the College develop policies and procedures to address this issue. These policies should require that an individual, separate from the reporting of enrollment status changes, review a listing of all students with enrollment status changes on a periodic basis to determine these changes and have been properly reported within the allotted time frame as required by the U.S. Department of Education. The College should also enforce its attendance taking policy to ensure that all student withdrawals are reported in a timely manner to the Financial Aid Office. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: The Financial Aid Office will continue the procedure implemented last year of including all institutional educational-related charges on the R2T4 form when processing student withdrawals and calculating amounts of federal aid to be returned. The Financial Aid Office will once again reemphasize, to the appropriate campus personnel, the importance of following the College's attendance-taking policy, and communicating that attendance information to the Registrar on a timely basis so as to allow the determination of the last date of class attendance (and therefore the effective date of withdrawal) required for the completion of the Student Withdrawal Form the Financial Aid Office uses to calculate and return Title IV funds in accordance with U.S. Department of Education regulations. In order to ensure that students who are not attending classes are reported timely to the Financial Aid Office so that Title IV withdrawal calculations can be performed as required, the College will adopt procedures requiring the Registrar?s Office to do the following (1) when a student is reported on ?early warning? in one class for non-attendance, query all of the student?s professors about their attendance in those classes, and (2) when a student is reported for a third or fourth absence in one class, query all of the student?s professors about their attendance in those classes. The Financial Aid office will be notified promptly when such inquiries indicate that a student is not attending multiple classes and may be a candidate for a status change. Proposed Completion Date: For enhanced communication of timely attendance communication to the Registrar and Financial Aid: 6/30/2020 in time for the start of the new academic year.
2018-002
The College does not have a written procurement policy. Criteria: Under Title 2, U.S Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR Parts 200.317 through 200.326, the financial management system of each non-federal entity must have a written procurement policy. Cause of Condition: The College does not have a written policy that meets the Uniform Guidance requirements. Effect of Condition: The College is not in compliance with the Uniform Guidance. Recommendation: We recommend the College develop and implement a written procurement policy to comply with the requirements of the Uniform Guidance. The policy should be clearly documented and available for all College staff to follow. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Show full finding ▾Hide full finding ▴Finding 2019-002: Written Procurement Policy ? (significant deficiency) Statement of Condition: The College does not have a written procurement policy. Criteria: Under Title 2, U.S Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR Parts 200.317 through 200.326, the financial management system of each non-federal entity must have a written procurement policy. Cause of Condition: The College does not have a written policy that meets the Uniform Guidance requirements. Effect of Condition: The College is not in compliance with the Uniform Guidance. Recommendation: We recommend the College develop and implement a written procurement policy to comply with the requirements of the Uniform Guidance. The policy should be clearly documented and available for all College staff to follow. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.
Corrective Action: Lyon College has requested copies of sample procurement policies from external sources. Management will review those and develop one which can be promptly implemented. Proposed Completion Date: Lyon College will implement the above procedure by 6/30/2020, in time for the start of the next fiscal year.
FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on February 27, 2018 — management decision was due August 27, 2018.
GSA_MIGRATION
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