College of Biblical StudiesNon-Profit

2022-001 Compliance and Internal Controls over Cash Management (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425E ? COVID-19 Student Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. Condition: We noted that for all 25 of the disbursements reviewed, the payments to students were processed after the fifteen calendar day timeframe. Effect: While HEERF funding has been exhausted as of June 30, 2022, not issuing refunds within due dates may impact future federal funding levels for the College. Cause: Issues with communications between the business office and student financial aid department and system issue with the student software caused delays in processing payment to students. Questioned Costs: None. Perspective: Systemic problem noted for all disbursements made to students arising from communication issues between the College?s departments and student software issues. Repeat Finding: No Auditors? Recommendation: While not applicable for HEERF funding since this has been fully utilized, for all related federal awards to students, we recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Views of Responsible Officials: See corrective action plan

2022-002 Internal Controls over Suspension and Debarment (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425F ? COVID-19 Institutional Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a) and 2 CFR Section 180, Subpart C, non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: The College does not have documented controls to prevent purchases using federal funds from suspended or debarred vendors. Effect: Payments from federal funds made to suspended or debarred vendors may need to returned and / or impact future funding. Cause: While the College has policies and procedures for procurement, these do not encompass verifying that the potential vendor is suspended or debarred from receiving federal funding as required under 2 CFR Section 180, Subpart C. Questioned Costs: None. Perspective: Because a formal policy is not established, none of the vendors meeting the threshold were subjected to suspension and debarment testing by the College. Repeat Finding: No Auditors? Recommendation: The College should establish procedures to ensure that controls related to suspension and debarment are devised, are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Views of Responsible Officials: See corrective action plan

2021-001 Compliance and Internal Controls over Disbursements (Significant Deficiency) U.S. Department of Education Cluster of Programs ? Student Financial Assistance 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 2020-2021 Funding Criteria: Under 2 CFR Section, 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Additionally, under 34 CFR 668.164(h)(2), the Department of Education requires educational institutions to refund credit balances on student accounts related to Title IV federal aid funds no later than 14 days after the date the credit balance occurred on the student's account, if the credit balance occurred after the first day of class of a payment period, or the first day of classes of the payment period, if the credit balance occurred on or before the first day of class of that payment period. Condition: We noted that for 8 out of the 40 disbursements reviewed, the refunds to students were not processed timely. The College?s established controls over the disbursement process did not work effectively to detect and / or correct these non-compliances over the disbursement process. Effect: Not issuing refunds within due dates may impact future funding levels for the College. Cause: During the fiscal year, the Business Office experienced issues in the transition from XLedger accounting system to Financial Edge (FE) accounting system. In addition, the student enrollment management system was changed from SONIS to Campus Nexus Student. The issue with the transition in accounting systems prevented a check from being printed in a timely manner for 1 of the 8 exceptions noted. For 6 of the 8 exceptions noted, the Business Office experienced a system wide issue with FE which prevented all checks requested during this period from being printed in a timely manner. For 1 of the 8 exceptions, additional time was needed to review the refund calculation to ensure the amount was correct before disbursement to the student. Questioned Costs: None. Perspective: The deficiency in internal controls over timely refunds of credit balances was due to the changes in systems and the associated issues that occurred. Repeat Finding: No Auditors? Recommendation: We recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Views of Responsible Officials: The Title IV financial aid business processes will be modified to align cash draws through G5 by third-party processor Global Financial Aid Services, Inc. (Global) following financial aid student aid reviews associated with eligible aid disbursements processed by Global. This activity will be supported by documented student aid detailed reconciliation reports.

2020-001 Internal Controls over Enrollment Reporting (Significant Deficiency) U.S. Department of Education Cluster of Programs ? Student Financial Assistance 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 2019-2020 Funding Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally, under 34 CFR Section 685.309(a), participating schools must establish and maintain proper administrative and fiscal procedures to maintain compliance with student financial assistance programs, including direct loan programs, and submit all reports required under these programs within the prescribed timeframe to the Department of Education. Condition: Enrollment reports for December 2019 and March 2020 were not submitted timely. Additionally enrollment reports for April 2020, May 2020 and June 2020 were not submitted as of the date of our review. The College?s established controls over the enrollment reporting process did not work effectively to detect and / or correct these non-compliances over the enrollment reporting process. Effect: This information is important to the National Student Clearinghouse because it lets them know which students are still working towards their degree, and which students are no longer enrolled (either from graduating or dropping out). This information needs to be known because students have a six month grace period after the time they are no longer enrolled and after this grace period is over, student loans must start being repaid. This report also allows the College to determine whether a student has withdrawn and therefore return of funds may be necessary. Cause: Turnover in the College?s registrar position, primarily responsible for submission of enrollment reports, resulting in lapses over the enrollment reports submission process. Questioned Costs: None. Auditors? Recommendation: We recommend that the College formally devise a monthly schedule for submission of enrollment reports. The Director of Student Financial Aid should be responsible for adherence to these reporting requirements. Views of Responsible Officials: The College requested an extension with the institution?s representative at National Student Clearinghouse to submit the missing enrollment reports. Missing enrollment reports were submitted and schedule enrollment reports have been submitted on time.

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