2025-001: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency) Assistance Listing Numbers/Titles: #84.268, Federal Direct Student Loans, and #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: July 1, 2024 - June 30, 2025 Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information, including that previously provided by the student and the institution.” Per 34 CFR 685.309(b), “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.” Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.” Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.” Condition/context: Of the 11 students selected for testing of accurate enrollment reporting, we noted the following errors: • One instance in which the student was reported as withdrawn with the incorrect effective date; • Two instances in which the student was not reported within 60 days of the date of determination; and • One instance in which the student was reported with the incorrect enrollment status. Cause: The Student Financial Aid and Registrar Offices do not have sufficient controls in place to ensure the proper and timely reporting of student status changes. Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status. III. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS, Continued Questioned costs: None. Identification as a repeat finding: Yes. See finding 2024-002. Recommendation: The Student Financial Aid and Registrar Offices should implement additional controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
The independent auditor identified certain concerns as set forth in the SFA Enrollment Reporting Control Deficiency, dated June 30, 2025. All concerns appear to relate to mid-semester withdrawals of students; all will be resolved by the continued implementation of previous corrective action plan (CAP) and the facilitation of the additional plan details set forth herein. As background to these issues, Eastern Wyoming College (EWC) experienced unique circumstances related to the transmission of student information as a result of its status on Heightened Cash Monitoring (HCM2). Simply, the systems in place between the college, the federal government, and a third-party vendor did not communicate accurately, principally due to timing issues of student information and EWC's requests for reimbursement of financial aid. In the previous audit (2023-24), these types of issues were identified and remedied through EWC's corrective action plan. At that time, EWC committed to manually updating the Clearinghouse/NSLDS systems to ensure timely enrollment reporting. This effort was put in motion beginning in October 2024. EWC submits the concerns identified in the latest report were largely being corrected by the previous plan and the resolution of the timing issues due to EWC's move from HCM2 to HCM1 statuses. As part of EWC's continued effort, it is worthwhile to note additional information, issues and resolutions. Enrollment reporting at EWC has been historically managed by the Data Analyst. This singular reporting has allowed data to be reported consistently and efficiently. However, because the analyst does not work in either the Registrar or Financial Aid Offices, the reporting has not been able to adeptly identify and address unusual cases. The current reporting structure requires additional review and oversight. Therefore, as part of corrective actions, the Registrar or designee will manage enrollment statuses for all mid-semester college withdrawals. The Registrar is in the best position see the student's enrollment and to identify the accurate dates. The Registrar will be the final decision maker regarding the reporting of information. In addition, the Financial Aid Office, as part of their R2T4 calculation checklist when an official withdrawal form exists, will ensure that any completed courses from Block A do not impact the student's reported status of withdrawn. The Financial Aid Director, either as part of the initial calculation or the follow-up internal audit, will confirm whether any credits are earned prior to a student's withdrawal. Further, the director will ensure that any withdrawal is separately reported because current, standard reporting may not identify this status change. Delayed reporting as noted in the associated finding, will no longer be an issue now that all systems are aligned following the college's move from HCM2 to HCM1 status. This allows National Student Loan Data System (NSLDS) to be notified of awarded aid, which will then allow the National Student Clearinghouse to effectively report all students, as required. In addition to the systems working as designed, EWC will conduct an internal audit each semester and will review students who withdrew during the term to ensure that all systems were updated correctly, and all offices reported accurate dates. In addition, all offices involved will create a collective Standard Operating Procedure manual related to enrollment reporting in addition to each office's separately documented procedures. Anticipated Completion Date: September 2025 Contact Person: Rebecca McAllister/Xi Feng/Dave Bluemel
2024-002
2024-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency) Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #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: July 1, 2023 - June 30, 2024 Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.” Per 34 CFR 685.309(b), “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.” Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.” Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.” Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.” Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors: • Two instances in which the students were not reported as withdrawn at the Program-Level; • One instance in which the student’s published program length was incorrect; • One instance in which the student was reported as withdrawn with the incorrect effective date; and • Three instances in which the student was not reported within 60 days of the date of determination. Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes. Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status. Questioned costs: None. Identification as a repeat finding: Yes. Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective actions: Eastern Wyoming College currently has a service arrangement with National Student Clearinghouse (NSC) to provide enrollment reporting to the National Student Loan Data System (NSLDS) per the requirements outlined in CFR 690.83 (b)(2), 685.309(b), and per the NSLDS Enrollment Reporting Guide. These regulations require institutions to report changes in enrollment within a 60-day period. In fulfilling these requirements, EWC's Data Analyst utilizes reports in Colleague to complete the enrollment reporting requirements and submit these reports to NSC. This occurs every thirty days, which exceeding meets the 60-day requirement. EWC's Office of Institutional Research, through the Data Analyst, works with the Registrar and the Financial Aid Office to review and resolve any reporting errors with NSC. Historically, this process worked with minimal errors, but the HCM2 processes posed some unforeseen challenges in the reporting process. To meet these challenges, the Data Analyst sends the student rosters to the NSC. If the students on the SSCR roster are not part of the NSLDS database as a current borrower or recipient of federal student aid, then the Data Analyst must manually upload the information to the NSLDS instead of relying on NSC to initiate the reporting. The Student Financial Aid and Registrar Offices have implemented controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, EWC will directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider. For instances where students program length was not reporting correctly, this was resolved at the end of 2022-2023 award year, and the Financial Aid office updated all the Colleague screens used to pull the reports utilized by Institutional Research in submitting the report. EWC has developed and distributed Standard Operating Procedures to ensure the withdrawal dates reported in each office are using the same information. Anticipated completion date: October 2024 Contact person: Rebecca McAllister/Xi Feng
2023-002
2024-003: Student Financial Aid Cluster – Reporting - Fiscal Operations Report and Application to Participate (FISAP) (Significant Deficiency) Assistance Listing Numbers and Titles: #84.077, Federal Supplemental Educational Opportunity Grants, and #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: July 1, 2023 - June 30, 2024 Criteria: Per 34 CFR 673.3(a), to participate in the Federal Perkins Loan, Federal Work Study (FWS), or Federal Supplemental Educational Opportunity Grants (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. Per 34 CFR 673.3(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 FISAP, we noted that the amount reported for Part II, Section E - Total Tuition and Fees for the award year from July 1, 2022 to June 30, 2023 was overstated by $189,992. Cause: The Student Financial Aid and Business Offices did not have controls in place to ensure accurate amounts were reported the FISAP. Effect: Errors on the FISAP report could result in the loss and/or miscalculation of future Federal funding. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid and Business Offices should implement a system of controls related specifically to the supporting documentation utilized in the FISAP submission. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective actions: The Financial Aid Office has historically received a copy of the Fund 10 and Fund 13 ledgers from the Business Office and then calculated the tuition and fees, making sure to remove the concurrently enrolled students and inapplicable fees. This calculation was completed without knowledge that some of the Fund 13 Fees pass through and are already included the Fund 10 details. This resulted in a number of Fund 13 Fees being counted twice. This process has been corrected starting with the 24-25 FISAP. The CFO and Financial Aid Director worked together and the CFO calculated the tuition and fees for Part II Section E of the FISAP. This ensured the correct calculation and eliminated the inclusion of fees that were flowing through the two different GL fund accounts. Anticipated completion date: September 30,2024 Contact person: Rebecca McAllister/Kwin Wilkes
2023-001: Special Tests - Number of Students Served (Significant Deficiency) Assistance Listing Number and Title: #84.334, Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): University of Wyoming Award Number/Name: P334S170010-21 Award Year: September 26, 2021 - September 25, 2022 Criteria: Per the Sub-Award Agreement between the University of Wyoming and Eastern Wyomign College (the College or the Contractor), “Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students: • GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).” Condition/context: The number of students served by the College during the year was recorded at 327, an underserving of 23. Cause: The College has historically been able to meet the minimum required number of students served via internal tracking, as well as via subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR-UP program experienced a turnover in the director position (including a more-than-two-month vacancy). As such, the program struggled to recruit and retain students served via the program. Additionally, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure the minimum required number of students were being served. Effect: The University of Wyoming could opt to not renew the College’s program funding if the minimum required number of students served is not met. Questioned costs: None. Identification as a repeat finding: Yes. See prior-year finding 2022-004. Recommendation: We recommend that the program have a process in place to ensure that all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective actions: In response to the previous Corrective Action Plan, the following have been implemented and are in progress: - Enrollment rates have increased by 29 students from January 2023, showing improvement in recruiting and retention. - EWC GEAR UP lost its director in April 2023, which impacted the push for recruitment and retaining students. - As of June 19, a new Director was hired for GEAR UP. - Since hiring the new Director, three additional schools have agreed to participate in GEAR UP services. This will increase student enrollment and engagement by an estimated 25 students by the end of 2023. - Two additional Coordinators will be hired at EWC. Coordinators will serve EWC GEAR UP freshmen as well as local schools without GEAR UP advisors (Torrington High School and Lingle/Ft. Laramie Middle and High School), which will increase enrollment and engagement by an estimated 25 students by the end of 2023. - Coordinators will attend parent-teacher conferences to aid staff in recruiting and retaining students and families in the GEAR UP Program. - Coordinators will be able to assist with events and family programs. - Current advisors have agreed to return for the year of September 2023-September 2024. This will decrease hiring and orientation times and allow for more recruiting from those school advisors. Anticipated completion date: June 2024 Contact person: GEAR UP Director - Chelsea Ballard
2022-004
2023-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency) Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #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: July 1, 2022 - June 30, 2023 Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.” Per 34 CFR 685.309(b), “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.” Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.” Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.” Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.” Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors: • Two instances in which the students were not reported as withdrawn; • One instance in which the student’s published program length was incorrect; and • Two instances in which the reported Program Begin Date did not match institution records. Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes. Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective actions: EWC Financial Aid actively addressed the issue of awards not showing in the Common Origination and Disbursement (COD) system. EWC has implemented a new process utilizing the Colleague Transfer Monitoring system to ensure NSLDS accepts the NSC enrollment information. In the event that EWC’s HCM2 status prevents automatic reporting, EWC Financial Aid will update NSLDS monthly. Completion date: October 2023 Contact person: Financial Aid Director - Rebecca McAllister ________ Student with reported program length: EWC has set internal controls to ensure the proper settings within Colleague are selected, including setting years as a default instead of months. EWC Financial Aid and EWC Academic Services will review and evaluate each program and ensure that the proper default is selected to ensure accurate program reporting. Anticipated completion date: December 2023 Contact people: Financial Aid Director - Rebecca McAllister and Admin. Specialist - Lynn Wamboldt _________ Students with a program date from Colleague that did not match NSLDS: The Colleague student-information system will be updated to define the parameter of start date as the first day of each semester. This software patch will ensure Colleague matches the reporting parameters utilized by NSLDS. Anticipated completion date: January 2024 Contact people: Data Analyst - Xi Feng and CIO -Tyler Vasko
2023-003: Student Financial Aid Cluster - Special Tests: Disbursements to, or on Behalf of, Students (Significant Deficiency) Assistance Listing Number and Title: #84.268, Federal Direct Student Loans Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year: July 1, 2022 - June 30, 2023 Criteria: Per 34 CFR 668.165, if the institution disburses funds that include Federal Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, unsubsidized loans, and PLUS loans. The institution must notify the student or parent of (i) the anticipated date and amount of the disbursement, (ii) the student’s or parent’s right to cancel all or a portion of that loan, and (iii) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. The institution must provide the notice no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution. Condition/context: During our review of students who were disbursed Federal direct loans, we noted two students in which the College did not provide written notification to borrowers regarding loan disbursements within 30 days prior/subsequent to the disbursement. Both instances of missed notification occurred in spring 2023. Cause: The Student Financial Aid Office did not have sufficient controls in place to ensure that notifications were provided and records were maintained. Effect: The borrower is not aware of the anticipated disbursement date or amount, their right to cancel all or a portion of the loan, or the procedures to follow to cancel the loan if necessary. Questioned costs: None. Identification as a repeat finding: No. Recommendation: The Student Financial Aid Office should develop a process to ensure that timely written notification is provided to borrowers regarding loan disbursements and that documentation of notification is maintained. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective actions: In September 2023, EWC Financial Aid implemented a permanent fix utilizing the Colleague Process Handler, which automates disbursement notifications. The automated disbursement process is set to run weekly and ensures time sensitive acknowledgement to aid recipients. Completion date: September 2023 Contact person: Director of Financial Aid - Rebecca McAllister
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency) Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster Federal Agency Name: U.S. Department of Education Pass-Through Entity Name (if applicable): N/A Award Number/Name: N/A Award Year: July 1, 2022 - June 30, 2023 Criteria: 16 CFR 314.3 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 to 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 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part. Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4. Cause: The College does not have a control in place to ensure that policies are reviewed and revised 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 implement a control to monitor changes in Federal guidelines in order to update policies timely. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
Corrective actions: As a result of a cyber-event in 2021 and a program review conducted by the U.S. Department of Education, EWC initiated a comprehensive assessment of information technology and security to ensure compliance with the Gramm-Leach-Bliley Act (GLBA) and industry protocols. EWC hired an educational law firm, Parker & Poe and Associates, to evaluate and prepare policies in accordance with legal requirements. These policies, Board Policies 7.0 through 7.5 (as renumbered), have been reviewed within the College administration and presented to the Board of Trustees for first reading in October 2023. EWC anticipates the final approval and adoption will occur on December 12, 2023. Additionally, EWC foresees finalizing supporting administrative regulations on or before December 31, 2023. The policies and regulations are designed to ensure a comprehensive information security plan and GLBA compliance while meeting the requirements of the U.S. Department of Education. Anticipated completion dates: December 12, 2023 (Policies) and December 31, 2023 (Regulations) Contact person: Vice President Administrative Services - Patrick Korell
See Schedule of Findings and Questioned Costs for chart/table 2022-003: Reporting Criteria: 2 CFR 200.327, Financial Reporting, and the laws, regulations, and provisions of contracts or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable), and submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) were required to publicly post certain information on their websites 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. IHEs posting a 45-day report on or after August 31, 2020 should instead post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. IHEs may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if they have 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. IHEs 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 each institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were reviewed and approved by proper authorized individuals or that the reports were completed and submitted timely. 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 receiving 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. Identification as a repeat finding: Yes; see prior-year finding 2021-002. Recommendation: We recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
2022-003 Reporting Condition: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Correction: With respect to item #1, internal controls will be implemented for a second review of all quarterly reports by a member of the business office to verify accuracy before being submitted to the Department of Education and uploaded to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021. Items #2-4 reference reports that were not reported in a timely manner. Reminders in the calendar have been created to ensure completion of the reports. Information has also been shared with the College webmaster as to when reports need to be uploaded for timely submissions. Internal controls will be used to verify accuracy of data with the financial aid office, but also a final review that shows actual submission of the reports to the Department of Education and to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021.
2021-002
See Schedule of Findings and Questioned Costs for chart/table 2022-004: Special Tests - Number of Students Served Criteria: Per the Sub-Award Agreement between the University of Wyoming and the College (the Contractor), ?Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students: ? GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).? Condition/context: The number of students served by the College during the year was recorded at 298, an underserving of 52. Questioned costs: $0 Cause: Historically, the College has been able to meet the minimum required students served via internal tracking as well as subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR UP program experienced turnover in the director position and other matters impacted the ability of the former outreach coordinator/database technician to perform her normal duties. As such, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure that the minimum number of students were being served. Effect: The University of Wyoming could opt to not renew the College?s program funding if the minimum number of students served requirement is not met. Identification as a repeat finding: No Recommendation: We recommend that the program have a process in place to ensure all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
2022-004: Special Tests - Number of Students Served Condition/context: The number of students served by the College during the year was recorded at 298, an underserving of 52. Correction: After collaboration and brainstorming with the team from UW, the following corrective actions were suggested: ? Actively host recruitment events that specifically target grade levels 7th - 12th ? Educate school principals about the GU program, having their support will likely encourage increased student participation ? Develop and hire school-site advisors in schools that do not currently have a GU program Encourage school-site advisors to be present at sporting events and parent-teacher conferences to visit with students and parents about the benefit of the program ? Host monthly meetings and/or county-wide events, meetings, or educational field trips
See Schedule of Findings and Questioned Costs for chart/table Criteria: 2 CFR 200.327 - Financial Reporting; and the laws, regulations, and provisions of contracts 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 compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: Quarterly Public Reporting (Student Portion): Institutes of Higher Education (IHE) were required to publicly post certain information on their 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 their 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 they have 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, except for 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: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. The Quarterly Institutional report for the period ended December 31, 2020 incorrectly reported expenditures that were not incurred during the period. 2. The Quarterly Institutional report for the period ended December 31, 2020 incorrectly transposed the sum of the expenditure categories when reporting the total quarterly expenditures. 3. The Quarterly Institutional report for the quarter ended June 30, 2021 was not submitted in a timely manner and was not conspicuously posted on the College?s website. Questioned costs: $0 Cause: The College?s internal control system did not have a sufficient control process in place to ensure all reports were accurate or a sufficient control process to review the reports for propriety to identify errors. 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 receiving 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. Identification as a repeat finding: No. Recommendation: We recommend that the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.
With respect to the first two items, internal controls will be implemented by VP for Administrative Services, Kwin Wilkes, for a second review of all quarterly reports by a member of the business office to verify accuracy before being submitted and uploaded to the EWC website. This will be implemented for the next quarterly report submission, which will be in October 2022. Item #3 references a report that was due June 30, 2021. This report was due a bit over a week after EWC had experienced a cyber-event. The College lost access to all data, which was not until months later. The College did not complete this report in a timely manner as it did not have access to data. Thus, there were extenuating circumstances. Also, reminders have been set up in the calendaring system by VP for Administrative Services, Kwin Wilkes to ensure completion and submission of timely reports.
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