EIN: 830204417
UEI: YHVDDNQFHS65
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 23, 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 June 23, 2026 (65 days ago).
What is a management decision? →Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement. Condition/context: Of the 27 students selected for Pell reporting testing, four students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement. Cause: Due to turnover within the Student Financial Aid Director position during the year, the students were not reported timely in the COD system. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-002. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement. Condition/context: Of the 27 students selected for Pell reporting testing, four students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement. Cause: Due to turnover within the Student Financial Aid Director position during the year, the students were not reported timely in the COD system. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-002. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Western Wyoming Community College experienced an unexpected turnover in the Director position which impacted the timeliness of reporting. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of reporting to COD within the 15 day period after disbursing federal aid. • Any available funds are disbursed each Monday throughout the semester, except for when a holiday falls on a Monday. Funds are then disbursed on the next working business day. • The process to export these disbursements to the Department of Education are performed the same day or the following day after the Business office has ran the transmittal process. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been exported to the Department of Education through the Common Origination and Disbursement (COD) portal the Assistant Director or Director of Financial will to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed until accepted by COD. This process will ensure the timely reporting to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid
2024-002
Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary. Condition/context: The Student Financial Aid Program was unable to provide documentation for Direct Loan reconciliations that had been completed during the year. Cause: Due to turnover within the Student Financial Aid Director position, and due to ongoing systematic issues with accessing the COD system, the Student Financial Aid Office was unable to provide sufficient documentation that Direct Loan reconciliations were submitted to the COD system during the year. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, if not completed on a regular basis, the College is at risk of not meeting disbursement reporting and excess cash deadlines. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-003. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations and retain associated support. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary. Condition/context: The Student Financial Aid Program was unable to provide documentation for Direct Loan reconciliations that had been completed during the year. Cause: Due to turnover within the Student Financial Aid Director position, and due to ongoing systematic issues with accessing the COD system, the Student Financial Aid Office was unable to provide sufficient documentation that Direct Loan reconciliations were submitted to the COD system during the year. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, if not completed on a regular basis, the College is at risk of not meeting disbursement reporting and excess cash deadlines. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-003. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations and retain associated support. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who did not retain documentation for completed reconciliations, no reconciliations were available for review for the 2024/2025 Academic Year and 2025 Fiscal Year. Corrective Action Plan 1. Staffing and Training a. A new Director of Financial Aid has been hired and has completed training on the reconciliation process for both Pell Grants and Direct Loans in collaboration with the Assistant Director of Financial Aid. b. Cross-training has been implemented to ensure continuity of operations in the event of future staff turnover. 2. Establishment of Standard Operating Procedures (SOP) a. The Financial Aid Office has worked with the Business/Bursar’s Office to develop and document a Standard Operating Procedure (SOP) governing: • The drawdown of Title IV funds. • The reconciliation process for Pell and Direct Loan programs. b. The SOP outlines responsible parties, required documentation, and timelines for reconciliation and reporting. 3. Monthly Reconciliation Schedule a. A reconciliation schedule has been established requiring completion of Pell and Direct Loan reconciliations by the 15th of each month, or as soon thereafter as federal reports become available. b. Once reconciliations are confirmed as accurate and complete with the Business/Bursar’s Office, drawdowns of funds will occur on or near the 15th of each month, depending on calendar dates and federal system availability. 4. Compliance Alignment a. This process ensures timely and accurate reconciliation of Pell Grant and Direct Loan funding in accordance with 34 CFR 685.300(b)(5) and related federal cash management requirements. Anticipated Completion Date: November 15, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, Assistant Director of Financial Aid, Business/Bursar’s Office
2024-003
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary. Condition/context: Of the 17 students selected for testing: • One student’s withdrawn status was not reported to NSLDS. • One graduated student was not reported properly as such at the Campus Level. • Five students were not reported to NSLDS with an accurate withdrawal date. • Two students’ status changes were not reported within 60 days of the date of determination. • Two students’ program start dates were not reported accurately. Cause: The Student Financial Aid Office and Records and Registration do not have consistent controls in place to ensure the proper and timely reporting of student status changes. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-005. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary. Condition/context: Of the 17 students selected for testing: • One student’s withdrawn status was not reported to NSLDS. • One graduated student was not reported properly as such at the Campus Level. • Five students were not reported to NSLDS with an accurate withdrawal date. • Two students’ status changes were not reported within 60 days of the date of determination. • Two students’ program start dates were not reported accurately. Cause: The Student Financial Aid Office and Records and Registration do not have consistent controls in place to ensure the proper and timely reporting of student status changes. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period. Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-005. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar
2024-005
Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred later than 45 days after the institution determines that the student withdrew. Condition/context: Of the 13 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew. Cause: The Student Financial Aid Office did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and return unearned Title IV aid to the U.S. Department of Education timely. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: Yes. See 2024-004. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred later than 45 days after the institution determines that the student withdrew. Condition/context: Of the 13 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew. Cause: The Student Financial Aid Office did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and return unearned Title IV aid to the U.S. Department of Education timely. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: Yes. See 2024-004. Recommendation: The Student Financial Aid Office should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Western Wyoming Community College experienced an unexpected turnover in the Director position and had a consultant from Dynamic Campus and an Interim Director of Financial Aid step in to help assist staff during this time. Due to lack of communication, reporting of a return of Title IV funds for the one student found in the audit did not occur as it normally would. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of Return to Title IV and timely reporting. • Each day the total withdrawal list is checked to determine the students who are receiving federal aid and may need to have a Return of Title IV calculation performed. • The students who are determined to require a Return of Title IV calculation are then processed for the Return of Title IV funds. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been adjusted appropriately the Assistant Director or Director of Financial immediately run the process to export the files and funds out to the Common Origination and Disbursement (COD). • The next day COD is checked to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed to be accepted by COD. This process will ensure the timely reporting and return of funds to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid
2024-004
FAC accepted this audit on December 18, 2024 — management decision was due June 18, 2025.
Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary. Per the Fiscal Operations Report for 2022-23 and Application to Participate for 2024-25 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D. Condition/context: Tuition and fees for the award year July 1, 2022 to June 30, 2023 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $68,880,369. The correct amount was $6,880,369. Cause: Human error. Effect: If Western Wyoming Community College (the College) fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the U.S. Department of Education. The school may be required to return funds to which it is not entitled. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a thorough system of review of the FISAP to ensure that accurate information is reported. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 675.19(b)(3) and 676.19(b)(3), each year an institution shall submit a Fiscal Operations Report plus other information the Secretary requires. The institution shall insure that the information reported is accurate and shall submit it on the form and at the time specified by the Secretary. Per the Fiscal Operations Report for 2022-23 and Application to Participate for 2024-25 Instructions for Part II (Application) Section E, the tuition and fees revenue entered must only be for those students reported in Section D. Condition/context: Tuition and fees for the award year July 1, 2022 to June 30, 2023 reported under Part II (Application) Section E of the Fiscal Operations Report and Application to Participate (FISAP) was incorrectly reported as $68,880,369. The correct amount was $6,880,369. Cause: Human error. Effect: If Western Wyoming Community College (the College) fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, incorrect reporting in the FISAP may result in incorrect award calculations by the U.S. Department of Education. The school may be required to return funds to which it is not entitled. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a thorough system of review of the FISAP to ensure that accurate information is reported. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
2024-001: Reporting This finding is the result of human error when completing the Fiscal Operations Report and Application to Participate (FISAP). An extra digit was added to the tuition/fees charged, changing the tuition and fees charged from $6,880,369 to $68,880,369. This was missed in the review of the FISAP prior to submission. Corrective Action: The Financial Aid Office took great care in reviewing the 2023-2024 (for 2025-2026) FISAP for accuracy. Additionally, the amount requested for SEOG and FWS is the exact same as requested on the 2022-2023 (for 2024-2025) FISAP, rather than the inflated fair share. The Financial Aid Office will request up to the fair share on the 2024-2025 (for 2026-2027) FISAP. This issue has been successfully addressed. Anticipated Date of Correction: 9/30/2024 Contact Person: Shanna Vargas, Director of Financial Aid
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement. Condition/context: Of the 25 students selected for Pell reporting testing, 19 students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement. Cause: During the transition of Financial Aid Directors, an error occurred in the assignment of the Primary Destination Point Administrator that resulted in an inability to import and export from Colleague to Student Aid Internet Gateway (SAIG) for COD and National Student Loan Data System (NSLDS) reporting. During this time, the College was unable to export disbursement information in a timely manner, which caused a delay in the COD processing of disbursement records. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Per the Federal Student Aid Handbook, schools must submit Pell disbursement records to the Common Origination and Disbursement (COD) system no later than 15 days after making the disbursements or becoming aware of the need to adjust a previously reported disbursement. Condition/context: Of the 25 students selected for Pell reporting testing, 19 students’ disbursement records were reported to the COD system greater than 15 days after the actual disbursement. Cause: During the transition of Financial Aid Directors, an error occurred in the assignment of the Primary Destination Point Administrator that resulted in an inability to import and export from Colleague to Student Aid Internet Gateway (SAIG) for COD and National Student Loan Data System (NSLDS) reporting. During this time, the College was unable to export disbursement information in a timely manner, which caused a delay in the COD processing of disbursement records. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, failure to submit disbursement records within the required time frame may result in a rejection of all or part of the reported disbursement, an audit or program review finding, or possible fines or other penalties. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a thorough control system that provides for the timely reporting of disbursement records to the COD system. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
2024-002: Reporting This finding is a result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Part of this issue reflected SAIG/CPS/COD/NSLDS access from being set up correctly and resulted in many hours of contact and meetings with SAIG professionals to correct. Corrective Action: The Financial Aid Office has worked with SAIG professionals to correct this issue. The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid
Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary. Condition/context: Direct Loan reconciliations were not completed for six months of the fiscal year - the months of January 2024 through June 2024. Additionally, support for Direct Loan reconciliations that had been completed was not maintained during the year. Cause: During the transition of Student Financial Aid Directors during the year, there was an issue in which the SAIG was unavailable to the Financial Aid Director due to previous access at another institution. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, if not completed on a regular basis, the school is at risk of not meeting disbursement reporting and excess cash deadlines. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations that includes process and procedures in place to complete monthly reconciliations when the main point of contact or access to SAIG and COD is not available. Additionally, the College should develop procedures and requirements to maintain monthly Direct Loan reconciliations and associated support. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 685.300(b)(5), to participate in the Direct Loan Program, a school must, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to, and accepted by, the Secretary. Condition/context: Direct Loan reconciliations were not completed for six months of the fiscal year - the months of January 2024 through June 2024. Additionally, support for Direct Loan reconciliations that had been completed was not maintained during the year. Cause: During the transition of Student Financial Aid Directors during the year, there was an issue in which the SAIG was unavailable to the Financial Aid Director due to previous access at another institution. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, if not completed on a regular basis, the school is at risk of not meeting disbursement reporting and excess cash deadlines. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a process to complete monthly Direct Loan reconciliations that includes process and procedures in place to complete monthly reconciliations when the main point of contact or access to SAIG and COD is not available. Additionally, the College should develop procedures and requirements to maintain monthly Direct Loan reconciliations and associated support. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
2024-003: Cash Management This finding is the result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Corrective Action: The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: 8/19/2024 Contact Person: Shanna Vargas, Director of Financial Aid
Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred no later than 45 days after the institution determines that the student withdrew. Condition/context: Of the 12 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew. Cause: The College did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and that unearned Title IV aid was returned to the U.S. Department of Education timely. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 668.173 (b), an institution returns unearned Title IV program funds timely if the funds are transferred no later than 45 days after the institution determines that the student withdrew. Condition/context: Of the 12 students selected for testing, one student’s unearned aid was not returned to the U.S. Department of Education within 45 days of the date the institution determined that the student withdrew. Cause: The College did not have a process in place to monitor and review official and unofficial withdrawals and ensure that a return of Title IV funds calculation had been performed for all withdrawn students and that unearned Title IV aid was returned to the U.S. Department of Education timely. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a system to review students for withdrawal on a timely and consistent basis in order to properly determine withdrawal dates and return unearned Title IV aid in a timely manner. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
2024-004: Return of Title IV Funds This student’s late calculation was due to the failure to review withdrawal reports during the changeover in director responsibilities. All students that fail to earn any credit during the semester are reviewed at the end of each semester. This student was found at that point, and the calculation was completed. Corrective Action: The withdrawal report is reviewed at minimum each week by the Financial Aid Office and R2T4s are calculated timely. This issue has been resolved. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid
Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary. Condition/context: Of the 16 students selected for testing: • Two students’ withdrawn status was not reported to NSLDS. • Three students were not reported to NSLDS with an accurate withdrawal date. • One student’s program length was improperly reported as 2.5 years rather than two years. Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period. Questioned costs: None. Identification as a repeat finding: Yes - see finding 2023-003. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials and planned correction actions: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Additionally, per 34 CFR 685.309, upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary (i) in the manner and format prescribed by the Secretary, and (ii) within the timeframe prescribed by the Secretary. Condition/context: Of the 16 students selected for testing: • Two students’ withdrawn status was not reported to NSLDS. • Three students were not reported to NSLDS with an accurate withdrawal date. • One student’s program length was improperly reported as 2.5 years rather than two years. Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes. Effect: If the College fails to comply with the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, as described in 2 CFR 200.208, or implement other remedies for noncompliance, as described in 2 CFR 200.339. Additionally, the improper reporting of student status changes could impact students’ repayment status and/or maximum eligibility period. Questioned costs: None. Identification as a repeat finding: Yes - see finding 2023-003. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials and planned correction actions: Management concurs with the finding. See Exhibit I.
2024-005: Enrollment Reporting Unofficially withdrawn students (students who failed to earn credit during the term) are reviewed after the end of the semester, and R2T4 is calculated, where required. However, there was not a process in place for the Registrar to update the Enrollment Reporting as a result of the review process. Corrective Action: As part of the process of reviewing these students and performing the R2T4 calculation, the Financial Aid Office will send a report of unofficially withdrawn students to the Registrar to ensure that enrollment reporting is appropriately updated. Anticipated Date of Correction: Immediately Contact People: Shanna Vargas, Director of Financial Aid, and Kayla Miller, Registrar
2023-003
FAC accepted this audit on January 26, 2024 — management decision was due July 26, 2024.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution. Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid. Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans. Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors. Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding. Questioned costs: $9,218 Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution. Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid. Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans. Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors. Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding. Questioned costs: $9,218 Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Pell This finding is the result of manual awarding and revisions by staff that are no longer employed by WWCC. To prevent Pell underpayment, Colleague was reconfigured for 2023-2024 to accurately award and revise awards when students add courses prior to the census date. Additionally, a regular review of the Pell Eligibility Variance Report in Colleague (which displays students with a Colleague calculated Pell that differs from what the student has been awarded) will identify any student not awarded to their full Pell eligibility. Loan This finding is the result of a miscalculation of single term costs of attendances (COA) for students enrolling spring only. To address the 2022-2023 overpayments identified, all students enrolled for the spring single term while receiving Title IV funding had their COA recalculated, financial need determined using the four (4) month EFC, and SEOG, and subsidized/unsubsidized loan eligibility recalculated. Where required, the SEOG, and subsidized/unsubsidized loans were adjusted to actual eligibility and the student account and COD updated. Documentation that this action was completed has been provided to the auditor. For 2023-2024, Colleague was reconfigured to calculate COA components at a per term level, instead of at an annual level (which was used in 2022-2023). Colleague was also reconfigured to calculate the EFC for a single term student so that the financial need could be determined correctly. As a result, single term students will receive a single term COA and EFC to accurately the student’s financial need. SEOG and subsidized/unsubsidized loans will be awarded based on financial need and remaining costs. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part. Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4. Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines. Effect: The College is not compliant with the Gramm-Leach-Bliley Act. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part. Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4. Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines. Effect: The College is not compliant with the Gramm-Leach-Bliley Act. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Point of Contact In an email to President’s Cabinet on July 10th, 2023, Dr. Kim Kuster Dale designated Derek Robinson, Chief Information Officer for Western Wyoming Community College as the responsible party for GLBA, replacing the previous owner and coordinator: Financial Aid Director. Contact information: Derek Robinson Chief Information Officer Western Wyoming Community College cio@westernwyoming.edu 307-382-1896 Resource Requirements Correcting the audit findings identified in the 2022-2023 fiscal year audit requires participation from the Chief Information Officer, Vice President for Student Services, Associate Vice President of Finance, Dean of Students, Financial Aid Director, Associate Vice President of Human Resources, and Chief Academic Officer. The budget for any corrective actions and findings is yet unknown. The technical system requirements identified in the GLBA on June 9, 2023 (GENERAL-23-09), were underway and largely completed before the audit including the incorporation of the NIST 800-171 security standards. A draft of the Information Security Program also existed prior to June 30th, 2023. However, the College did not publish or complete the Information Security Program due to staff turnover. Planned Milestones The important milestones for this corrective action plan are aligned with the Information Security Program scope. Successful implementation of these categories and acceptance by the Program Coordinators indicates completion of the milestone. More detailed information about the goals and outcomes for each category can be found in the attached document. 1.Risk identification and assessment and current safeguards. 2.Risk assessment. 3.Information security controls. 4.Security awareness and training. 5.Incident response and data breach notification. 6.Vendor management. 7.Monitoring and auditing. 8.Program evaluation and improvement. 9.Sign the attestation form on the SAIG portal indicating that the College is now fully GLBA compliant. Scheduled Completion Date The Information Security Program will be developed and accepted by the end of December 2023, to be compliant with the requirements of the signature of attestation for the SAIG-FTI enrollment statement, and to be eligible to enroll in the data exchange for the processing systems for ISIR files. The ISIR files need to be processed in January, which require access to the SAIG portal, which requires signing a confirmation that the college meets all GLBA requirements. Status The following tasks and updates have been completed since the President designated the CIO as the responsible party: 1.July 2023 – Information Security Program draft created (attached to this email). 2.August 2023 – Reviewed the policy-defined membership list indicates many people that should not be on this team, and many people that should be on the team and are not included. Proposing new membership to members, then presenting to P&P committee for changes. 3.September 2023 – Goals for Information Security Program drafted. New GLBA requirements reviewed and included in draft Information Security Program. 4.October 2023 – CIO and Information Security Analyst identified and written several protocols to address some initial findings, including account termination procedures, use of AI and related technologies on campus, and authentication mechanisms. 5.November 2023 – Corrective Action Plan identified for previous year’s audit findings. Meeting dates set to finish the Information Security Program. Anticipated Completion Date: December 31, 2023 Contact Person: Derek Robinson, Chief Information Officer
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.” Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.” Condition/context: Of the 10 students selected for enrollment reporting testing: • One student’s withdrawn status was not reported to NSLDS. • Two students’ withdrawn and graduated statuses were not reported timely to NSLDS. • Two students’ program lengths were improperly reported as 3.214 years rather than two years. Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes. Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.” Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.” Condition/context: Of the 10 students selected for enrollment reporting testing: • One student’s withdrawn status was not reported to NSLDS. • Two students’ withdrawn and graduated statuses were not reported timely to NSLDS. • Two students’ program lengths were improperly reported as 3.214 years rather than two years. Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes. Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Prior to the 2023-2024 academic year, the Registrar has completed several trainings regarding reporting and has developed and implemented a schedule to ensure timely and accurate reporting to National Student Clearinghouse as well as resolving any errors in a timely manner. As of the 2023-2024 academic year, this institution is reporting withdraw dates and student status changes accurately. Through research and training, the program length is currently being updated to reflect 2 years or 4 years rather than reporting in months. This reporting change was put into place prior to the final submission of 2023 Fall. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public. Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database. Cause: The College was unaware of the requirement. Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Show full finding ▾Hide full finding ▴Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public. Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database. Cause: The College was unaware of the requirement. Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public. Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
WWCC cannot confirm that the Bank Mobile contract was provided to the Department of Education (ED) as required due to staff turnover. However, WWCC has ended the contract with Bank Mobile and beginning with the Spring 2024 semester, credit balance refunds will be issued by EFT using bank account information provided by the student or by check issued by WWCC if the student does not provide a bank account in TouchNet. TouchNet does not open any accounts or offer any debit cards to issue credit balance refunds to WWCC students. WWCC will ensure that all ED reporting requirements are met for the Touchnet contract. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management
FAC accepted this audit on December 14, 2021 — management decision was due June 14, 2022.
See Schedule of Findings and Questioned Costs for chart/table 2021-001: Education Stabilization Fund Assistance Listing (AL) Number and Title: AL 84.425 Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: P425F201276 and P425E201122 Award Year(s): May 29, 2020 - May 12, 2022 and April 23, 2020 - May 12, 2022 Criteria: 2 CFR 200.327 Financial reporting, and the laws, regulations, and provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and be submitted in accordance with the appropriate deadlines. Per various guidance published by the U.S. Department of Education, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Annual Reporting: The HEERF Data Collection Form was required to be submitted to ED via the Annual Report Data Collection System on February 8, 2021 and applied to the reporting period from March 13, 2020 through December 31, 2020. Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) was required to publicly post certain information on its website no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Instead of posting a 45-day report on or after August 31, 2020, IHE should post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after its last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. IHE may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if it has not already done so. Quarterly Public Reporting (Institutional Portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHE must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on the institution s primary website on the same page the reports of IHE s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: The required Quarterly Public Reporting for the Institutional Portion (AL #84.425F) and the Student Portion (AL #84.425E) of HEERF grant funds was not completed. Questioned costs: $0 Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Cause: The College s internal control system did not have a sufficient control process in place to ensure all reports were accurate and properly posted to the College s website or a sufficient control process to review the reports. Identification as a repeat finding: No. Recommendation: We recommend that the College implement procedures to ensure required reporting is completed. Additionally, we recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted. Views of responsible officials and planned corrective actions: See Exhibit I.
Show full finding ▾Hide full finding ▴See Schedule of Findings and Questioned Costs for chart/table 2021-001: Education Stabilization Fund Assistance Listing (AL) Number and Title: AL 84.425 Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: P425F201276 and P425E201122 Award Year(s): May 29, 2020 - May 12, 2022 and April 23, 2020 - May 12, 2022 Criteria: 2 CFR 200.327 Financial reporting, and the laws, regulations, and provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and be submitted in accordance with the appropriate deadlines. Per various guidance published by the U.S. Department of Education, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Annual Reporting: The HEERF Data Collection Form was required to be submitted to ED via the Annual Report Data Collection System on February 8, 2021 and applied to the reporting period from March 13, 2020 through December 31, 2020. Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) was required to publicly post certain information on its website no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Instead of posting a 45-day report on or after August 31, 2020, IHE should post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after its last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. IHE may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if it has not already done so. Quarterly Public Reporting (Institutional Portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHE must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on the institution s primary website on the same page the reports of IHE s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: The required Quarterly Public Reporting for the Institutional Portion (AL #84.425F) and the Student Portion (AL #84.425E) of HEERF grant funds was not completed. Questioned costs: $0 Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Cause: The College s internal control system did not have a sufficient control process in place to ensure all reports were accurate and properly posted to the College s website or a sufficient control process to review the reports. Identification as a repeat finding: No. Recommendation: We recommend that the College implement procedures to ensure required reporting is completed. Additionally, we recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted. Views of responsible officials and planned corrective actions: See Exhibit I.
2021-001: Education Stabilization Fund Reporting The Quarterly Public Reporting for the Institutional Portion (AL 84.425F) has been updated and reported on our website under Consumer Information, CARES Act Reporting for the 4th quarter 2020, 1st quarter 2021, 2nd quarter 2021, and 3rd quarter 2021. The Quarterly Public Reporting for the Student Portion (AL 84.425E) has been updated and reported on our website under Financial Aid, CARES Act Reporting. The reports here include: 1) 1st, 2nd, and 3rd quarters for 2021 2) 4th quarter for 2020 3) 30-day report 4) 45-day report
See Schedule of Findings and Questioned Costs for chart/table 2021-002: Education Stabilization Fund Assistance Listing (AL) Number and Title: AL 84.425 Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: P425F201276 and P425E201122 Award Year(s): May 29, 2020 - May 12, 2022 and April 23, 2020 - May 12, 2022 Criteria: 2 CFR 200.318 The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or sub-award. The non-Federal entity s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Per 2 CFR 200.320, the non-Federal entity may use informal procurement methods for the procurement of property or services at or below the simplified acquisition threshold as defined in 2 CFR 200.1, including micro-purchases or small purchases. When the value of the procurement for property or services exceeds the simplified acquisition threshold, formal procurement methods are required, including sealed bids, proposals or noncompetitive procurement. Condition/context: During our review of two vendors selected for testing compliance with procurement requirements, we were not able to verify that the College documented following Federal procurement requirements for the two vendors. The College did not document rationale for sole sourcing. It was noted that the Board of Trustees granted temporary powers to the president to forgo internal policies surrounding entering into contracts, as long as such action was applicable with State and Federal laws, which included the authority to sole source contracts due to expediency and necessity during the pandemic, which applied to these vendors. Questioned costs: $0 Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; require additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Cause: The College s internal control system did not have a sufficient control process in place to ensure Federal procurement requirements were followed. Identification as a repeat finding: No. Recommendation: We recommend the College implement internal control procedures to ensure Federal procedures. This includes cases in which the Board of Trustees grants temporary or other such powers to forgo internal policy. Views of responsible officials and planned corrective actions: See Exhibit I.
Show full finding ▾Hide full finding ▴See Schedule of Findings and Questioned Costs for chart/table 2021-002: Education Stabilization Fund Assistance Listing (AL) Number and Title: AL 84.425 Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: P425F201276 and P425E201122 Award Year(s): May 29, 2020 - May 12, 2022 and April 23, 2020 - May 12, 2022 Criteria: 2 CFR 200.318 The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or sub-award. The non-Federal entity s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Per 2 CFR 200.320, the non-Federal entity may use informal procurement methods for the procurement of property or services at or below the simplified acquisition threshold as defined in 2 CFR 200.1, including micro-purchases or small purchases. When the value of the procurement for property or services exceeds the simplified acquisition threshold, formal procurement methods are required, including sealed bids, proposals or noncompetitive procurement. Condition/context: During our review of two vendors selected for testing compliance with procurement requirements, we were not able to verify that the College documented following Federal procurement requirements for the two vendors. The College did not document rationale for sole sourcing. It was noted that the Board of Trustees granted temporary powers to the president to forgo internal policies surrounding entering into contracts, as long as such action was applicable with State and Federal laws, which included the authority to sole source contracts due to expediency and necessity during the pandemic, which applied to these vendors. Questioned costs: $0 Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; require additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Cause: The College s internal control system did not have a sufficient control process in place to ensure Federal procurement requirements were followed. Identification as a repeat finding: No. Recommendation: We recommend the College implement internal control procedures to ensure Federal procedures. This includes cases in which the Board of Trustees grants temporary or other such powers to forgo internal policy. Views of responsible officials and planned corrective actions: See Exhibit I.
2021-002: Education Stabilization Fund Procurement To address possible future issues in the compliance federal purchasing requirements associated with federal grant monies, the College has updated its procedures and communications, as follows: 1. Key positions responsible for procurement decision-making, the Administrative Services Officer, the Vice President of Administrative Services and the College President, have all been made aware of the procurement and documentation requirements under Uniform Grant Guidance and the need to follow these requirements regardless of local board action for all future procurement actions. 2. A draft policy revision will be submitted to address procurement specifically related to the use of federal grant monies and the separate requirements thereof.
See Schedule of Findings and Questioned Cost for chart/table 2021-003: Education Stabilization Fund Suspension and Debarment AL Number and Title: AL #84.425 Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: P425F201276 and P425E201122 Award Years: May 29, 2020 - May 12, 2022 and April 23, 2020 - May 12, 2022 Criteria: The College must design internal controls to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Per 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Condition/context: There were five vendors with aggregate expenditures greater than $25,000 during the year under audit. Of those five vendors, two were selected for testing compliance with the suspension and debarment requirements. Of those two vendors, one vendor did not have a suspension and debarment clause in the contract and College staff did not perform other verification procedures to ensure the vendor was not suspended or debarred. This is not a compliance finding, as the vendor was not suspended or debarred. Questioned costs: $0 Effect: If the College is not verifying that vendors with which it contracts are neither suspended nor debarred, it is possible that the College could contract with a vendor that is suspended or debarred, in which case the College may be required to return the funds expended to that vendor to the Federal oversight or pass-through agency. Cause: The College s internal control system did not have a sufficient control process in place to ensure that a suspension and debarment clause was included in the contract. Identification as a repeat finding: No. Recommendation: We recommend the College implement internal control procedures to ensure operation procedures. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
Show full finding ▾Hide full finding ▴See Schedule of Findings and Questioned Cost for chart/table 2021-003: Education Stabilization Fund Suspension and Debarment AL Number and Title: AL #84.425 Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: P425F201276 and P425E201122 Award Years: May 29, 2020 - May 12, 2022 and April 23, 2020 - May 12, 2022 Criteria: The College must design internal controls to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Per 2 CFR 200.214, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR Section 180.215. Condition/context: There were five vendors with aggregate expenditures greater than $25,000 during the year under audit. Of those five vendors, two were selected for testing compliance with the suspension and debarment requirements. Of those two vendors, one vendor did not have a suspension and debarment clause in the contract and College staff did not perform other verification procedures to ensure the vendor was not suspended or debarred. This is not a compliance finding, as the vendor was not suspended or debarred. Questioned costs: $0 Effect: If the College is not verifying that vendors with which it contracts are neither suspended nor debarred, it is possible that the College could contract with a vendor that is suspended or debarred, in which case the College may be required to return the funds expended to that vendor to the Federal oversight or pass-through agency. Cause: The College s internal control system did not have a sufficient control process in place to ensure that a suspension and debarment clause was included in the contract. Identification as a repeat finding: No. Recommendation: We recommend the College implement internal control procedures to ensure operation procedures. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
2021-003: Education Stabilization Fund Suspension & Debarment In order to mitigate further issues in the compliance of contracts executed with federal grant monies regarding suspension and debarment of vendors, the College has updated its procedures and communications by completing the following: 1. There are several key positions through which contracts for the majority goods or services are awarded: the Administrative Services Officer, the Director of Information Technology and the Vice President of Administrative Services. These three positions have been made aware of the requirement per 2 CFR 200.214 regarding suspension and debarment and the need for it to be included in vendor contracts moving forward. 2. The Grants & Accounting Technician will now be checking each vendor paid with federal grant money for suspension and debarment using SAM.gov for verification. That verification will be attached with the normal paperwork received during the accounts payable process. 3. The Funded Project form that is required to be completed for every grant will be updated to include key information regarding the necessary contract clause or additional verification required for suspension and debarment. Anticipated Completion Date: June 30, 2022 Contact Persons: Burt Reynolds, VP of Administrative Services, and Debbie Baker, AVP of Finance
FAC accepted this audit on February 4, 2021 — management decision was due August 4, 2021.
2020-001: Student Financial Aid Cluster Catalog of Federal Assistance (CFDA) Numbers and Titles: 84.268 Federal Direct Student Loans 84.063 Federal Pell Grant Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year(s): July 1, 2019 ? June 30, 2020 Criteria: Per 1.3 of the National Student Loan Data System Enrollment Reporting Guide, ??schools are required to report all Title IV aid recipients? enrollment at the program-level in addition to the campus-level.? Per review of 34 CFR 685.305 (FDL), the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83 (Pell), an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Condition/Context: Of the seventeen students tested for Enrollment Reporting, we noted three instances where the student?s status change was reported with an inaccurate status effective date. In the first two instances, there were 2-day and 1-day differences and in the third instances, a 15-day difference. Questioned Costs: $0 Effect: Improper reporting of student status changes could impact the student?s interest subsidy and/or repayment status. Cause: In the three instances noted above, the following contributed to the errors in reporting: controls not fully in place to ensure the appropriate effective date of the student status change was reported, controls not fully in place to identify manual entry errors, and controls not fully in place to ensure all student status changes are reported accurately. In addition, the Student Financial Aid Office does not have adequate review procedures in place over the student status changes reported to the National Student Loan Data System. Identification as a Repeat Finding: Yes. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure proper and timely reporting of student status changes. We also recommend there be a process in place prior to the submission of student status changes to ensure accuracy of any manual information input. Views of Responsible Officials and Planned Corrective Actions: See Exhibit I.
Show full finding ▾Hide full finding ▴2020-001: Student Financial Aid Cluster Catalog of Federal Assistance (CFDA) Numbers and Titles: 84.268 Federal Direct Student Loans 84.063 Federal Pell Grant Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year(s): July 1, 2019 ? June 30, 2020 Criteria: Per 1.3 of the National Student Loan Data System Enrollment Reporting Guide, ??schools are required to report all Title IV aid recipients? enrollment at the program-level in addition to the campus-level.? Per review of 34 CFR 685.305 (FDL), the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83 (Pell), an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Condition/Context: Of the seventeen students tested for Enrollment Reporting, we noted three instances where the student?s status change was reported with an inaccurate status effective date. In the first two instances, there were 2-day and 1-day differences and in the third instances, a 15-day difference. Questioned Costs: $0 Effect: Improper reporting of student status changes could impact the student?s interest subsidy and/or repayment status. Cause: In the three instances noted above, the following contributed to the errors in reporting: controls not fully in place to ensure the appropriate effective date of the student status change was reported, controls not fully in place to identify manual entry errors, and controls not fully in place to ensure all student status changes are reported accurately. In addition, the Student Financial Aid Office does not have adequate review procedures in place over the student status changes reported to the National Student Loan Data System. Identification as a Repeat Finding: Yes. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure proper and timely reporting of student status changes. We also recommend there be a process in place prior to the submission of student status changes to ensure accuracy of any manual information input. Views of Responsible Officials and Planned Corrective Actions: See Exhibit I.
2020-001: Student Financial Aid Cluster Enrollment Reporting Western Wyoming Community College Student Financial Aid has recently undergone a change in person holding the position of Director of Financial Aid. The new Director of Financial Aid has spent time working with our Institutional Effectiveness office and our Registrar to detail Records & Registration and Financial Aid processes and timelines. The Registrar and the Director of Financial Aid will be in constant communication regarding enrollment reporting and any necessary corrections that must be made to remain compliant. Western recognizes the benefits of using the National Student Clearinghouse to report enrollment; controls must be in place to ensure accurate reporting when using a third-party servicer. This year due to change over in staff the Financial Aid Officer will run the Summary Return of Funds Report (ROFS) out of Colleague and the Return to Title IV report every two weeks to ensure they match. The previous Director of Financial Aid would select a sample of 15-20 student each semester and audit files. The auditing to these 15-20 files was determined to not be as comprehensive as it needed to be. This process will now be more comprehensive in review. The Director of Financial Aid will audit files for eligibility, enrollment, Return to Title IV, and verification compliance. This will allow for a better determination of any potential audit/compliance issues internally. Updated End-of-Term Procedure With this updated process, both the Director of Financial Aid and the Registrar will provide oversight of the process. The Registrar will provide oversight of the National Student Clearinghouse and the Financial Aid Director will provide oversight of the National Loan Data System. ? This year the Financial Aid Officer along with the FA assistant to run an All F report after final grades are posted. ? The Financial Aid Officer and FA assistant will work together to calculate Return to Title IV. ? Provide R&R assistant the Return of Funds Report (ROFS) to verify last date of attendance, or withdrawal date matches the dates in Colleague. ? R&R assistant will verify students with subsequent semester enrollment and will continue to track enrollment throughout the subsequent semester, reporting any changes to the FA assistant. ? Financial Aid Officer and Financial Aid Assistant, will email the Registrar and Director of Financial Aid the final Return of Funds Report (ROFS) that has been signed off on by the R&R assistant, signifying all dates match in Colleague screens and are accurate for reporting. ? Registrar will first submit end-of-term enrollment reporting submission through the National Student Clearinghouse as usual. One week before the subsequent term begins, the Registrar will submit the end-of-term Return to Title IV (R2T4) list. This ensures that the report does not get overwritten by the previous and subsequent semester reporting. ? Increase internal audit file review. Those students returning for a subsequent semester ? 100% of files will be reviewed. These students are the most common reporting errors. The Financial Aid Director will pull 80% of the Return to Title IV (R2T4) files during the semester for review; this will be a priority over all other Director responsibilities. Status Date and Credential Date the Registration & Records office uses the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times a year, at the end of the spring, summer, and fall terms. It was determined that when the automatic graduation date is used, which is only able to be used when a student has only one program and no changes, the graduation date will populate correctly. All other students with multiple programs or changes to degree programs in the year, do not allow this option to be used and therefore, the wrong date is pulled out of Colleague. The process of uploading graduates and ensuring correct dates are being recorded will be handled by the Registrar. The Registrar and the Director of Financial Aid will review that the information is showing correctly for all of these students on the Clearinghouse and National Student Loan Data System (NSLDS) sites. Anticipated Completion Date: June 30, 2021 Contact Persons: Registrar-Stu Moore & Director of Financial Aid - DeeAnna Archuleta
2019-001
2020-002: Student Financial Aid Cluster Catalog of Federal Assistance (CFDA) Numbers and Titles: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year(s): July 1, 2019 ? June 30, 2020 Criteria: Per 34 CFR section 673.3 (a) To participate in the Federal Perkins Loan, FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the FEDERAL REGISTER. (b) The application for the Federal Perkins Loan, FWS, and FSEOG programs must be on a form approved by the Secretary and must contain the information needed by the Secretary to determine the institution?s allocation or reallocation of funds under sections 462, 442, and 413D of the HEA, respectively. Condition/Context: During our testing and review of the College?s Fiscal Operations Report and Application to Participate (FISAP), we noted that the total tuition and fees as reported in Part II Section E Line 22 was incorrectly reported as the prior year amount. We also noted that supporting documentation for FSEOG (columns e and f) and Unduplicated Recipients (column g) in Part VI was not retained. Questioned Costs: $0 Effect: Errors on the FISAP report could result in the loss and/or miscalculation of future Federal funding. Cause: The incorrect reporting of tuition and fees in Part II was caused by the lack of an independent review of the general ledger accounts that are used to substantiate the balance. The lack of retention of supporting documentation was caused due to a lack of controls requiring that the supporting documentation be maintained. Identification as a Repeat Finding: No. Recommendation: The Student Financial Aid Office should implement controls to independently review and perform reasonable checks on information obtained from other College departments. In addition, the Student Financial Aid Office should maintain all supporting documentation for information reported in the FISAP. Views of Responsible Officials and Planned Corrective Actions: See Exhibit I.
Show full finding ▾Hide full finding ▴2020-002: Student Financial Aid Cluster Catalog of Federal Assistance (CFDA) Numbers and Titles: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year(s): July 1, 2019 ? June 30, 2020 Criteria: Per 34 CFR section 673.3 (a) To participate in the Federal Perkins Loan, FWS, or FSEOG programs, an institution shall file an application before the deadline date established annually by the Secretary through publication of a notice in the FEDERAL REGISTER. (b) The application for the Federal Perkins Loan, FWS, and FSEOG programs must be on a form approved by the Secretary and must contain the information needed by the Secretary to determine the institution?s allocation or reallocation of funds under sections 462, 442, and 413D of the HEA, respectively. Condition/Context: During our testing and review of the College?s Fiscal Operations Report and Application to Participate (FISAP), we noted that the total tuition and fees as reported in Part II Section E Line 22 was incorrectly reported as the prior year amount. We also noted that supporting documentation for FSEOG (columns e and f) and Unduplicated Recipients (column g) in Part VI was not retained. Questioned Costs: $0 Effect: Errors on the FISAP report could result in the loss and/or miscalculation of future Federal funding. Cause: The incorrect reporting of tuition and fees in Part II was caused by the lack of an independent review of the general ledger accounts that are used to substantiate the balance. The lack of retention of supporting documentation was caused due to a lack of controls requiring that the supporting documentation be maintained. Identification as a Repeat Finding: No. Recommendation: The Student Financial Aid Office should implement controls to independently review and perform reasonable checks on information obtained from other College departments. In addition, the Student Financial Aid Office should maintain all supporting documentation for information reported in the FISAP. Views of Responsible Officials and Planned Corrective Actions: See Exhibit I.
2020-002: Student Financial Aid Cluster Fiscal Operations Report and Application to Participate (FISAP) The Director of Financial Aid has been working diligently with the Information Technology and the Institutional Effectiveness departments to ensure the accuracy of the Program Recipients Distribution Report (PRDR) obtained from Colleague. The IT department and the Financial Aid Director are meeting with an Ellucian Consultant to ensure all of infrastructure is correctly established for the Program Recipients Distribution Report (PRDR) report to run accurately. The Associate Vice President of Finance will provide a copy of all supporting documentation for Section E.22 of the FISAP to the Director of Financial Aid. A copy of this documentation will also be housed in the Business Office. The Director of Financial Aid and the Financial Aid Officer will review documentation and verify it matches what is being reported on the Fiscal Operations Report and Application to Participate (FISAP). The documentation will also be checked against last year?s numbers for reasonableness. The Information Technology office will save the PRDR report after it has been run for the final time and found to have no errors. The Financial Aid Director along with the Financial Aid Officer will validate the information from the PRDR report against a report that has been created by the Institutional Effectiveness Office to ensure accuracy. Once all data has been validated and deemed to be accurate the Director of Financial Aid and the Financial Aid Officer will sign a statement attesting to the accuracy of the FISAP prior to submission. The FISAP will be submitted and a copy retained along with all supporting documentation. Anticipated Completion Date: October 1, 2021 Contact Persons: DeeAnna Archuleta, SFA Director; Stu Moore, Registrar
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
2019-001: Student Financial Aid Cluster Catalog of Federal Assistance (CFDA) Numbers and Titles: 84.268 Federal Direct Student Loans; 84.063 Federal Pell Grant Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year(s): July 1, 2018 ? June 30, 2019 Condition/Context: Of the sixteen students tested for Enrollment Reporting, we noted two instances where the student?s status change was reported with an inaccurate status effective date. In the first instance, there was a 23-day difference and in the second instance, a 44-day difference. Of these two students, one student?s status change was reported on the 92nd day, rather than within 60 days as required. Within the same sample, we noted one instance where the student?s status change was not reported for the semester selected for testing. Criteria: Per 1.3 of the National Student Loan Data System Enrollment Reporting Guide, ??schools are required to report all Title IV aid recipients? enrollment at the program-level in addition to the campus-level.? Per review of 34 CFR 685.305 (FDL), the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83 (Pell), an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Questioned Costs: $0 Effect: Improper reporting of student status changes could impact the student?s interest subsidy and/or repayment status. Cause: In the three instances noted above, the following contributed to the errors in reporting: a lack of controls in place to ensure the appropriate effective date of the student status change was reported, a lack of controls in place to identify manual entry errors, and a lack of controls in place to ensure all student status changes are reported. In addition, the Student Financial Aid Office does not have adequate review procedures in place over the student status changes reported to the National Student Loan Data System. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure proper and timely reporting of student status changes. We also recommend there be a process in place prior to the submission of student status changes to ensure accuracy of any manual information input. Identification as a Repeat Finding: Yes. Views of Responsible Officials and Planned Corrective Actions: See Exhibit I (Corrective Action Plan).
Show full finding ▾Hide full finding ▴2019-001: Student Financial Aid Cluster Catalog of Federal Assistance (CFDA) Numbers and Titles: 84.268 Federal Direct Student Loans; 84.063 Federal Pell Grant Program Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year(s): July 1, 2018 ? June 30, 2019 Condition/Context: Of the sixteen students tested for Enrollment Reporting, we noted two instances where the student?s status change was reported with an inaccurate status effective date. In the first instance, there was a 23-day difference and in the second instance, a 44-day difference. Of these two students, one student?s status change was reported on the 92nd day, rather than within 60 days as required. Within the same sample, we noted one instance where the student?s status change was not reported for the semester selected for testing. Criteria: Per 1.3 of the National Student Loan Data System Enrollment Reporting Guide, ??schools are required to report all Title IV aid recipients? enrollment at the program-level in addition to the campus-level.? Per review of 34 CFR 685.305 (FDL), the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83 (Pell), an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Questioned Costs: $0 Effect: Improper reporting of student status changes could impact the student?s interest subsidy and/or repayment status. Cause: In the three instances noted above, the following contributed to the errors in reporting: a lack of controls in place to ensure the appropriate effective date of the student status change was reported, a lack of controls in place to identify manual entry errors, and a lack of controls in place to ensure all student status changes are reported. In addition, the Student Financial Aid Office does not have adequate review procedures in place over the student status changes reported to the National Student Loan Data System. Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure proper and timely reporting of student status changes. We also recommend there be a process in place prior to the submission of student status changes to ensure accuracy of any manual information input. Identification as a Repeat Finding: Yes. Views of Responsible Officials and Planned Corrective Actions: See Exhibit I (Corrective Action Plan).
Date: October 14, 2019 To: McGee, Hearne & Paiz, LLP From: Nicole Castillon SFA Director Re: Western Wyoming Community College Compliance Audit ? Fiscal Year 2019 2019-001: Student Financial Aid Cluster Enrollment Reporting Western Wyoming Community College Student Financial Aid has spent considerable time and resources dedicated to meeting the requirements of enrollment reporting. Our institution recognizes the benefits of using the National Student Clearinghouse to report enrollment; controls must be in place to ensure accurate reporting when using a third-party servicer. Previously, the Director of Financial Aid would select a sample of 15-20 student each semester and audit files. The main issue with the internal audit process is that the sample is more for general eligibility and awarding. In the future, additional R2T4 files and graduate files need to be selected. Moving forward, the Financial Aid (FA) Office and Records and Registration (R&R) will increase controls and create and end-of-term procedure in regard to all F, R2T4 calculations. The two students referenced in the finding having not been reported within the sixty days, were caused by reenrollment in a subsequent term and the other was a number transposed by a manual data entry on an Excel spreadsheet. These two errors could have been prevented by increasing controls. Updated End-of-Term Procedure With this updated process, both the Director of Financial Aid and the Registrar will provide oversight of the process. The Registrar will provide oversight of the National Student Clearinghouse and the Financial Aid Director will provide oversight of the National Loan Data System. ?FA assistant to run an All F report after final grades are posted. ?FA assistant to calculate R2T4 update Excel spreadsheet. ?Provide R&R assistant R2T4 files and spreadsheet to verify last date of attendance to be used as withdrawal date. ?R&R assistant will verify students with subsequent semester enrollment and will continue to track enrollment throughout the subsequent semester, reporting any changes to the FA assistant. ?FA assistant will email the Coordinator of Institutional Effectiveness the final R2T4 spreadsheet that has been reviewed by the R&R assistant. ?Coordinator of Institutional Effectiveness will first submit end-of-term enrollment reporting submission through the National Student Clearinghouse as usual. One week before the subsequent term begins, the Coordinator will submit the end-of-term R2T4 list. This ensures that the report does not get overwritten by the previous and subsequent semester reporting. ?Increase internal audit file review. Those students returning for a subsequent semester ? 100% of files will be reviewed. These students are the most common reporting errors. The Financial Aid Director will pull 50% off the R2T4 files during the semester for review; this will be a priority over all other Director responsibilities. Status Date and Credential Date The Registration & Records office uses UACF in Colleague to batch post student degrees and certificates three times a year, at the end of the spring, summer, and fall terms. Credential dates are placed on student records as indicated per proper date following each term. This is the correct date of graduation for students. It has been indicated in the audit that, although this date shows up correctly as the degree date on student transcripts, and the ?end date? in Colleague, unfortunately, the status date created is that of the day the process is run. This is causing the Clearinghouse to see the status date (transaction date) equal to the end date, as it is the one pulled during the end-of-term graduation reporting to them. If this process is run after the credential date the status date (transaction date) appears as the end date, it confuses matters. Our action plan moving forward is twofold: 1) Research possibility of systematizing process allowing for Status Date (transaction date) to equal Credential Date, regardless of date run; 2) If this is not possible, then Registration & Records will either process degree postings on the credential date, or manually update status dates to equal credential date as necessary. Anticipated Completion Date: June 30, 2020 Contact Persons: Nicole Castillon, SFA Director; Stu Moore, Registrar
2018-001
FAC accepted this audit on December 11, 2018 — management decision was due June 11, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on December 15, 2016 — management decision was due June 15, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-002
GSA_MIGRATION
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GSA_MIGRATION
2015-004
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