EIN: 751104546
UEI: GULXA55K4YK9
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. 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 March 30, 2026 (145 days ago).
What is a management decision? →We tested a sample of 40 students, of which 22 had Title IV credit balances during the year. For four of these 22 students, the Institution did not disburse the credit balances within the required timeframe. The sample was selected using a statistical methodology designed to achieve a 90% confidence level. The resulting error rate (18.2%) exceeded our materiality threshold of 10%. Further, this same issue was noted in a recent U.S. Department of Education program review. Accordingly, expanding the sample would not reduce the materiality of this finding. Criteria: In accordance with 34 CFR §668.164(e), when a Title IV credit balance exists, an institution must pay the credit balance directly to the student (or parent, if applicable) as soon as possible, but no later than 14 calendar days after:1. The balance occurs if it happens after the first day of classes of a payment period; or 2. The first day of classes of a payment period if the balance occurs on or before that day. Cause: This instance of noncompliance was due to an oversight in the Institution’s monitoring and disbursement process. Effect: Failure to timely disburse Title IV credit balances results in students not receiving financial aid funds when needed for educational and living expenses, potentially creating financial hardship. Questioned Costs: $0 –– Non-monetary compliance finding. Recommendation: The Institution should strengthen its monitoring and internal control procedures to ensure that Title IV credit balances are consistently identified and disbursed within the required timeframe. View of Responsible Officials: The Institution concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-001 Credit Balances Condition: We tested a sample of 40 students, of which 22 had Title IV credit balances during the year. For four of these 22 students, the Institution did not disburse the credit balances within the required timeframe. The sample was selected using a statistical methodology designed to achieve a 90% confidence level. The resulting error rate (18.2%) exceeded our materiality threshold of 10%. Further, this same issue was noted in a recent U.S. Department of Education program review. Accordingly, expanding the sample would not reduce the materiality of this finding. Criteria: In accordance with 34 CFR §668.164(e), when a Title IV credit balance exists, an institution must pay the credit balance directly to the student (or parent, if applicable) as soon as possible, but no later than 14 calendar days after:1. The balance occurs if it happens after the first day of classes of a payment period; or 2. The first day of classes of a payment period if the balance occurs on or before that day. Cause: This instance of noncompliance was due to an oversight in the Institution’s monitoring and disbursement process. Effect: Failure to timely disburse Title IV credit balances results in students not receiving financial aid funds when needed for educational and living expenses, potentially creating financial hardship. Questioned Costs: $0 –– Non-monetary compliance finding. Recommendation: The Institution should strengthen its monitoring and internal control procedures to ensure that Title IV credit balances are consistently identified and disbursed within the required timeframe. View of Responsible Officials: The Institution concurs with the finding. See corrective action plan.
Actions Taken / Planned The institution recognizes the importance of timely processing of Title IV credit balances and refunds. To address the deficiencies identified: 1. Short-Term Action (Current Practice): Effective immediately, all staff are required to submit for processing refunds within 24 hours of identifying a credit balance. Staff will also promptly correct any errors discovered during the reconciliation process. o Monitoring: Supervisors will conduct weekly reviews to ensure compliance with this 24-hour policy. o Training: Refresher training on Title IV credit balance processing has been provided to all relevant staff as of September 2025. o Instead of one ‘check run’ per week, numerous ‘check runs’ may be necessary to ensure 14 day window is met. 2. Long-Term Action (System Integration and Automation): The institution is actively working to integrate QuickBooks into our Student Information System (SIS) to automate Title IV and refund documentation. o This integration will streamline the reconciliation process, reduce manual errors, and ensure consistent, timely processing of refunds. o Projected Completion Date: Implementation and full automation are expected to be completed within 9–12 months, with a target date of September 2026. Expected Outcome: These measures will ensure timely and accurate processing of Title IV credit balances, improve compliance, and reduce the risk of future findings.
We tested a sample of 40 students, of which 12 required Federal Direct Loan (FDL) exit counseling. For two of these 12 students, the Institution did not timely perform the required exit counseling. The sample was selected using a statistical methodology designed to achieve a 90% confidence level. The resulting error rate (16.7%) exceeded our materiality threshold of 10%. Further, this same issue was identified in a recent U.S. Department of Education program review. Accordingly, expanding the sample would not reduce the materiality of this finding. Criteria: Per 34 CFR §685.304(b), institutions must ensure that each Direct Loan borrower completes exit counseling shortly before the student ceases at least half-time enrollment. Exit counseling must cover repayment options, debt management strategies, and the consequences of default. If the institution is unable to conduct the session prior to the student’s departure, the institution must mail or electronically provide exit counseling materials to the borrower within 30 days of learning that the student withdrew, graduated, or otherwise ceased to be enrolled at least half-time. Documentation of completion or notification must be maintained in the student’s file. Cause: The noncompliance occurred due to oversight during both graduation and withdrawal processes, resulting in exit counseling not being conducted or documented within the required timeframe. Effect: Failure to perform exit counseling increases the risk that students will not understand repayment obligations, raising the likelihood of loan default. Borrower defaults result in increased costs to the U.S. Department of Education. Questioned Costs: $0 –– Non-monetary compliance finding. Recommendation The Institution should strengthen its policies and monitoring controls to ensure exit counseling is consistently completed and documented for all Direct Loan borrowers upon withdrawal or graduation. View of Responsible Officials: The Institution concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2024-002 Exit Counseling. Condition: We tested a sample of 40 students, of which 12 required Federal Direct Loan (FDL) exit counseling. For two of these 12 students, the Institution did not timely perform the required exit counseling. The sample was selected using a statistical methodology designed to achieve a 90% confidence level. The resulting error rate (16.7%) exceeded our materiality threshold of 10%. Further, this same issue was identified in a recent U.S. Department of Education program review. Accordingly, expanding the sample would not reduce the materiality of this finding. Criteria: Per 34 CFR §685.304(b), institutions must ensure that each Direct Loan borrower completes exit counseling shortly before the student ceases at least half-time enrollment. Exit counseling must cover repayment options, debt management strategies, and the consequences of default. If the institution is unable to conduct the session prior to the student’s departure, the institution must mail or electronically provide exit counseling materials to the borrower within 30 days of learning that the student withdrew, graduated, or otherwise ceased to be enrolled at least half-time. Documentation of completion or notification must be maintained in the student’s file. Cause: The noncompliance occurred due to oversight during both graduation and withdrawal processes, resulting in exit counseling not being conducted or documented within the required timeframe. Effect: Failure to perform exit counseling increases the risk that students will not understand repayment obligations, raising the likelihood of loan default. Borrower defaults result in increased costs to the U.S. Department of Education. Questioned Costs: $0 –– Non-monetary compliance finding. Recommendation The Institution should strengthen its policies and monitoring controls to ensure exit counseling is consistently completed and documented for all Direct Loan borrowers upon withdrawal or graduation. View of Responsible Officials: The Institution concurs with the finding. See corrective action plan.
Actions Taken: The institution has implemented an automated process for Exit Counseling to ensure compliance with Title IV requirements. As of August 2025, the system has been configured to automatically send an exit counseling notification to students when they enter one of the following statuses: • Withdrawal • Graduation • Less than half-time enrollment System Workflow: When a student’s status changes, the system immediately generates and sends an email alert containing exit counseling instructions and the necessary links for completion. This ensures timely notification without requiring manual tracking by staff. Monitoring and Compliance: • Reports will be reviewed monthly to confirm that all required students received the exit counseling notifications. • Any discrepancies will be immediately investigated and resolved. Outcome: This automation eliminates the manual process previously in place, ensuring 100% notification compliance and greatly reducing the likelihood of future deficiencies in this area.
FAC accepted this audit on September 28, 2023 — management decision was due March 28, 2024.
The Colleges did not timely perform the required FDL exit counseling for 10 of 20 students in the sample requiring exit counseling. See Schedule of Findings and Questioned Costs for chart/table. Criteria: An in-person or on-line exit counseling session is required with each FDL borrower shortly before the student ceases enrollment on at least a halftime basis in order to emphasize the obligation and consequences of default. General information such as repayment options, consolidation, and debt management strategies must also be provided to the borrower. If the borrower withdraws/graduates without an institution?s prior knowledge and did not perform the exit counseling session, the institution must notify the borrower within 30 days after learning the borrower has withdrawn/graduated of their obligation. Institutions must document, in each student?s file, that the exit counseling or notification has been completed. Cause: This instance of noncompliance was due to the Institution not following its established polices and procedures as it pertains to exit counseling. Effect: An institution?s failure to provide exit loan counseling increases the possibility of a student defaulting on his or her loan. FDLs that go into default status create increased expense for the U.S. Department of Education. Recommendation: The Colleges should review and revise its procedures for performing exit counseling for all FDL recipients upon withdrawal/graduation. Views of Responsible Officials: The Colleges concur with the finding. See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-001 Exit Counseling Condition: The Colleges did not timely perform the required FDL exit counseling for 10 of 20 students in the sample requiring exit counseling. See Schedule of Findings and Questioned Costs for chart/table. Criteria: An in-person or on-line exit counseling session is required with each FDL borrower shortly before the student ceases enrollment on at least a halftime basis in order to emphasize the obligation and consequences of default. General information such as repayment options, consolidation, and debt management strategies must also be provided to the borrower. If the borrower withdraws/graduates without an institution?s prior knowledge and did not perform the exit counseling session, the institution must notify the borrower within 30 days after learning the borrower has withdrawn/graduated of their obligation. Institutions must document, in each student?s file, that the exit counseling or notification has been completed. Cause: This instance of noncompliance was due to the Institution not following its established polices and procedures as it pertains to exit counseling. Effect: An institution?s failure to provide exit loan counseling increases the possibility of a student defaulting on his or her loan. FDLs that go into default status create increased expense for the U.S. Department of Education. Recommendation: The Colleges should review and revise its procedures for performing exit counseling for all FDL recipients upon withdrawal/graduation. Views of Responsible Officials: The Colleges concur with the finding. See Corrective Action Plan.
A. Comments on Findings and Recommendations: Finding 2022-001 Exit Counseling Condition: The Institution did not timely perform the required FDL exit counseling for 10 of 20 students in the sample requiring exit counseling. PMC agrees with the condition outlined in Finding 2022-001 Exit Counseling. B. Prior Audit Findings There were no findings in the prior audit. C. Corrective Action Taken on Findings Finding 2022-001 Exit Counseling Current processes for exit counseling are to ensure graduating students receive exit counseling during the final quarter of enrollment as well as receive an e-mail with directions on how to complete exit counseling at www.studentloans.gov from the financial aid department. Students that are enrolled in less-than-halftime credits are also provided exit counseling when the quarter starts or known when the student drops down to that enrollment status through reduction of courses. When students withdraw they will be notified that they are to confirm whether or not a student has received direct loans or not; if yes, they are to perform their exit counseling duties. There has been a lack of quality assurance that has led to exit counseling being completed after 30 days for a variety of reasons. To correct this issue, PMC Registrar will run an enrollment status change report on a bi-weekly basis to catch any student that has changed to an out-of-school status and/or a less-than-half-time status to ensure the financial aid department completes their exit counseling phone call or in-person meeting, as well as their exit counseling e-mail with information regarding completing exit counseling via www.studentloans.gov. Within seven (7) days of the report being run, each student file will be checked to ensure exit counseling was completed and notes are placed within the file to verify exit counseling was completed within the 30 day period of the enrollment status change as required.
FAC accepted this audit on October 31, 2021 — management decision was due May 1, 2022.
The Institution did not timely perform the required Federal Direct Loan (FDL) exit counseling for six out of 15 students tested. Criteria: An in-person or on-line exit counseling session is required with each FDL borrower shortly before the student ceases enrollment on at least a half-time basis in order to emphasize the obligation and consequences of default. General information such as repayment options, consolidation, and debt management strategies must also be provided to the borrower. If the borrower withdraws/graduates without an institution?s prior knowledge and did not perform the exit counseling session, the institution must notify the borrower within 30 days after learning the borrower has withdrawn/graduated of their obligation. Institutions must document, in each student?s file, that the exit counseling or notification has been completed. Cause: Five of the six untimely exit counseling instances were due to an emergency change in staff at Mid-Atlantic College. One instance was at Gupton Jones College and is considered to be due to an oversight. Effect: An institution?s failure to timely provide exit loan counseling information increases the possibility of a student defaulting on his or her loan. FDLs that go into default status create increased expense for the U.S. Department of Education. Recommendation The Institution should review and revise its procedures for performing exit counseling for all FDL recipients upon withdrawal/graduation. View of Responsible officials The Institution concurs with the finding. See Corrective Action Plan for details.
Show full finding ▾Hide full finding ▴Finding 2020-001 Exit Counseling U.S. Department of Education, Federal Direct Loan Program 84.268 Condition: The Institution did not timely perform the required Federal Direct Loan (FDL) exit counseling for six out of 15 students tested. Criteria: An in-person or on-line exit counseling session is required with each FDL borrower shortly before the student ceases enrollment on at least a half-time basis in order to emphasize the obligation and consequences of default. General information such as repayment options, consolidation, and debt management strategies must also be provided to the borrower. If the borrower withdraws/graduates without an institution?s prior knowledge and did not perform the exit counseling session, the institution must notify the borrower within 30 days after learning the borrower has withdrawn/graduated of their obligation. Institutions must document, in each student?s file, that the exit counseling or notification has been completed. Cause: Five of the six untimely exit counseling instances were due to an emergency change in staff at Mid-Atlantic College. One instance was at Gupton Jones College and is considered to be due to an oversight. Effect: An institution?s failure to timely provide exit loan counseling information increases the possibility of a student defaulting on his or her loan. FDLs that go into default status create increased expense for the U.S. Department of Education. Recommendation The Institution should review and revise its procedures for performing exit counseling for all FDL recipients upon withdrawal/graduation. View of Responsible officials The Institution concurs with the finding. See Corrective Action Plan for details.
CORRECTIVE ACTION PLAN U.S. Department of Education FSA, eZ-Audit Room 74G2 Washington, D.C. 20202 Audit Firm: Salmon Sims Thomas & Associates, P.L.L.C. Audit Period: January 1, 2020 to December 31, 2020 A. Comments on Findings and Recommendations: Finding 2020-001 Exit Counseling FDL 84.268 Condition: The Institution did not timely perform the required Federal Direct Loan (FDL) exit counseling for six out of 40 students. PMC agrees with the condition outlined in Finding 2020-001 Exit Counseling. B. Actions Taken: Finding 2020-001 Exit Counseling Action Plan: PMC takes responsibility for not having a staff member available upon a time of another staff member?s emergency. PMC strives to have more than one staff member capable and trained to contact students regarding exit counseling. Dallas Institute and Gupton-Jones College has two (2) FT financial aid representatives; Mid-America College has had one (1) FT financial aid representative and been looking to hire a second with no success in 2020 and so far in 2021. Mid-America College will continue to search for a second staff member with the College?s office manager being there to assist with financial aid requirements if necessary In-person counseling for ground students is still requested prior to program completion or upon withdrawal, but for all students, follow-up e-mails (templates have been created and used) are being sent to the student within 14 days of their last date of attendance. Copies are to be saved in the staff members e-mails, notes added into our Student Information System (SIS) with date sent and by whom, and if student hard copy files are being retained, a copy added to the paper file.
FAC accepted this audit on September 24, 2019 — management decision was due March 24, 2020.
GSA_MIGRATION
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2017-003
FAC accepted this audit on September 10, 2018 — management decision was due March 10, 2019.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on August 15, 2017 — management decision was due February 15, 2018.
GSA_MIGRATION
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